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Netherlands — Orbitax Country Chapters Types of Partnerships and Hybrid Entities Available for International Business / Structuring

As mentioned above, the V.O.F. and C.V. are forms of Netherlands partnerships that can be useful in international business structuring. The V.O.F. in this respect will always be tax transparent, therefore the (foreign) partners will be obliged to file Netherlands tax returns. In contrast, a C.V. can be designed as a transparent or non-transparent entity. This is dependent on the terms and conditions of the private deed that normally will be drafted to constitute the C.V.

When one wishes to create a hybrid entity for business structuring, the C.V. will most likely be the appointed business form. To minimize dividend withholding taxes on outbound streams to non-EU countries, the cooperative is the appointed form to use, often in combination with a B.V. or N.V. However, the benefits of the CV structure have been eroded by various BEPS and ATAD inspired measures.