Are we required to report investor balances to the tax authorities?

The Dutch tax authorities use 2 main questions to determine who has to comply with those disclosure requirements, which is called 'renseignering' in Dutch:
1. Do you keep money or credit balances of your clients on your own account?
2. Are this balances administered by regular banks, funds or the Dutch 'beleggersgiro' structure?
In most cases, if both questions are positively answered, you are required to disclose. In general you have to keep in mind that the main goal/requirement is to provide individual investor balances to the authorities. Therefore banks will always be required regarding the account balances of their account holders. With individual portfolio management therefore the bank will be responsible for disclosure. In contrast, with collective investments, the bank will not be able to breakdown the collective balance to individual investors, and the administrator will be responsible. If we administrate your investment product or fund, we will of course apply with all requirements regarding this matter.


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