The Netherlands clarified VAT exemption rules for share transaction services, covering all stages of intermediation.
The Netherlands has published a new Decree on 15 October 2025 regarding the VAT exemption for share transactions.
The Decree clarifies the scope of “intermediary services” in securities transactions and provides a broad application of the VAT exemption. It applies when the service provider carries out activities across all stages of a transaction, including orientation and introduction, information and preparation, negotiation, and the conclusion of a contract.
According to established rulings of the Court of Justice of the EU, intermediation involves performing the necessary actions to enable parties to enter into a purchase or sale agreement. Activities qualify as intermediation if they involve finding a counterparty for remuneration with the purpose of facilitating the conclusion of a securities transaction.
Intermediation in a securities transaction can include:
- Informing a party about the opportunity to enter into a contract;
- Making contact with the other party on their behalf; and
- Negotiating the terms of the agreement in the name and on behalf of the party.
The Decree aims to clarify the circumstances under which the VAT exemption applies to services related to, but not limited to, the negotiation of shares or other securities.
The Decree entered into effect on 16 October 2025.
