Contact our Investment Management expert

Evert-Jan Spoelder
Partner

Partner
As a fund manager, private equity partner or institutional investor, you know that tax efficiency makes the difference between average and exceptional returns. Borgen Tax assists with complex tax aspects of investment structures, from fund formation to withholding tax compliance.
Our practical approach and direct contacts with tax authorities ensure that you can take advantage of tax opportunities within the framework of tax laws and regulations.
Investment Management focuses on tax advice to parties active in the financial services sector. It involves optimizing legal structures for investment funds, asset managers and their investors. For professional investors, strategic tax planning is crucial to:
The tax frameworks surrounding investment funds are constantly evolving. Without up-to-date expertise and proactive planning, you may be missing out on returns and running compliance risks.

In-depth knowledge of fund structures and private equity for concrete solutions that maximize after-tax returns.

Working directly with experienced partners for efficient communication and quick decisions without bureaucratic procedures.

Through Taxand Global direct access to specialists in 50+ countries for international structures and global withholding tax recoveries.
Fund form selection and structuring
Advice on choosing between different legal structures such as limited partnerships, cooperatives, limited liability companies or public limited companies. We analyze your investment goals, investor profiles and cash flow expectations to determine the optimal structure.
FBI/VBI regime optimization
Strategic guidance on the use of tax and exempt investment vehicles. We navigate you through the complex regulatory environment and anticipate changes such as the abolition of real estate FBIs by 2025.
Management, carried and co-investment structures
Structuring management, carried and co-investment structures. We provide tax-efficient structuring, including optimal treaty applications.
Withholding Tax Recovery
Professional guidance on recovering withholding tax withheld abroad on dividends and interest. We know the procedures in relevant jurisdictions and maximize your recoveries.
Treaty application and planning
Strategic planning for optimal application of tax treaties. We structure your international investments so that you take full advantage of treaty benefits
Certainty and rulings
Obtain advance certainty in complex domestic and cross-border structures.
Regulatory monitoring
Continuous monitoring of relevant tax developments including ATAD, DAC6, FATCA, CRS and anti-abuse regulations. We proactively inform you of changes affecting your structures.
Substance requirements and documentation
Support in meeting substance requirements for international structures. We provide adequate documentation and advice regarding operational substance.
Restructuring in the event of regulatory changes
Guidance on necessary adjustments to existing structures, such as restructuring real estate FBIs before 2025. We analyze alternatives and guide implementation.
Acquisition due diligence
Comprehensive tax analysis for investments by (pension) funds or acquisition of investment portfolios. We identify tax risks and optimization opportunities in advance.
Structure evaluations
Periodic review of existing fund structures for tax efficiency and compliance. We advise on improvement opportunities and anticipate future developments.
01
We analyze your investment goals, investor profiles and cash flow patterns to determine the optimal tax structure with concrete scenario comparisons.
Thorough analysis investment goals
Comparison of legal structures
FBI/VBI optimizations
02
Based on the analysis, we design efficient structures and coordinate proposed solutions in advance with the tax authorities where necessary.
Efficient structural design
Pros and cons comparison
Advance assurance through alignment
03
We accompany formation and provide all tax documentation, with ongoing support for tax compliance, restructuring and international coordination.
Full tax incorporation guidance
Continuous compliance support
International expertise through Taxand Global network
Discover how we helped a mid-sized asset manager design and launch a new institutional investment fund under tight timelines. Expert support on selecting the optimal fund structure, minimising withholding tax leakages, securing advance tax rulings, and meeting investor requirements.

Investment Management
An FBI (Fiscal Investment Institution) is a BV/NV structure taxed at 0% corporate income tax, with current profits distributed to unitholders through an annual pass-through obligation. A VBI (Exempt Investment Institution) is exempt from corporate income tax but has limitations, including liquidity and asset classes.
By using tax treaties, local legislation and correct procedures per country. We know the relevant procedures and systematically maximize your recoveries.
Real estate FBIs will no longer be allowed to invest directly in Dutch real estate as of 2025. We help restructure to alternative structures that will remain permitted.
This varies by jurisdiction, but generally required are: relevant economic activity, qualified personnel, adequate office space and local decision-making.
Depending on complexity and desired prior assurance, typically 6-12 weeks for standard structures and 3-6 months for complex international structures.
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