New policy note on intermediation in share transactions

• Clarification of VAT Treatment: The Dutch Tax Authorities have issued a new policy note clarifying that intermediation services in share transactions may qualify as VAT-exempt financial services, provided the intermediary is directly involved in bringing buyer and seller together.
• Substance Over Form: The exemption depends on the actual nature of the service, not just contractual labels. Intermediaries must demonstrate active involvement in the transaction process, such as negotiating terms or facilitating execution.
• Impact on Service Providers: This guidance affects financial advisors, brokers, and other intermediaries. Businesses should reassess their VAT position and documentation to ensure compliance with the clarified criteria.

Source Deloitte

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Netherlands Issues Guidance on VAT Exemption for Intermediation in Securities Transactions Effective October 2025

• New decree effective October 16, 2025, clarifies VAT exemption for intermediation in shares and securities transactions in the Netherlands.
• Exemption applies to service providers covering all four stages: orientation, information/preparation, negotiation, and contract conclusion.
• Interruption of the all-in process does not automatically disqualify the exemption.
• Services not covering all four stages or purely technical/substantive services (e.g., legal advice, business valuation) are not exempt.
• Aggregation of multiple third-party securities orders (e.g., on a stock exchange) is covered by the exemption.

Source: kpmg.com

Note that this post was (partially) written with the help of AI. It is always useful to review the original source material, and where needed to obtain (local) advice from a specialist.

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