The Dutch Mutual Fund Vehicle (FGR) for Family Investments

What an FGR is

A contractual fund rather than a legal person: participants contribute capital, a manager invests under written terms, a custodian (often a stichting) holds title, and each participant owns units. Entry and exit follow the fund terms — which makes the FGR the natural wrapper for a family securities pool spanning branches and generations.

The tax election that matters

Structured to the transparency conditions, the FGR itself stays outside corporate tax: results land directly at participant level — each branch’s holding under its own exemption, or private participants in box 3 above €59,357 per person. The 2025 modernisation tightened the definitions, so the terms are drafted to the current rules deliberately — one design session, once.

FGR or another BV?

The BV wins for operating stakes and control questions; the FGR wins for the pooled securities sleeve: lighter formation, units instead of notarial share transfers per movement, and clean branch accounting. Many family offices run both — holdings for the companies, an FGR for the portfolio — under the same governance: the architecture and the mandate.