Corporate income tax
1. Transitional regime for funds for joint account (FGR)
As of 1 January 2025, the definition of an FGR has been revised, most notably by eliminating the requirement for unanimous participant consent. As a result, some partnerships previously treated as fiscally transparent may now qualify as an FGR and become subject to corporate income tax. The government is considering refinements to narrow the FGR definition, potentially from 1 January 2027. If adopted, some of these partnerships could regain their transparent status. To avoid a brief period of tax opacity, a transitional opt-out regime is introduced. Partnerships that were transparent through 2024 may elect, retroactively from 1 January 2025, not to be treated as an FGR until the transitional rule expires (currently expected on 1 January 2028). Eligibility requires that the partnership was tax transparent before 2025, that its assets and income were attributed to participants, and that all participants provide consent by 28 February 2026. In practice, opting out means the partnership will not register as an FGR and will not file a corporate tax return for 2025.
2. Minimum capital rule
The minimum capital rule for banks and insurers will be amended. This provision limits interest deductibility for excessive debt financing. As of 1 January 2024, an exception was introduced allowing interest on intra-group loans to be deductible under certain conditions. However, this exception has proven too broad. As of 1 January 2026, the government proposes that loans directly related to financing from natural persons will cease to qualify for the exception. Consequently, interest payable on such loans will fall in scope of this interest deductibility rule.
3. Overlap between work-related costs scheme and the deduction limitation for mixed expenses
Currently, the deduction limitation for mixed expenses (such as costs for food, drinks, and entertainment) for corporate income tax purposes is determined by reference to the definition of wages as defined in the Dutch Wage Tax Act 1964 (Wet op de loonbelasting 1964). This approach has unintentionally broadened the base subject to the deduction limitation and made the system more complex. To address this, the limitation only applies in relation to wages for which wage tax is actually withheld.
Income tax
4. Adjustment of the lucrative interest scheme
The proposal introduces a tax base broadening multiplier for lucrative interests held through a substantial interest (at least 5% of paid-up share capital or any share class). The multiplier raises the effective Box 2 tax on benefits from indirectly held lucrative interests to as much as 36%.The regime will also be amended to prevent taxpayers from creating a substantial interest to offset substantial interest losses and thereby nearly eliminate tax on benefits from lucrative interests.
5. Adjustments and corrective legislation for Box 3
In 2021, the Dutch Supreme Court ruled that the current Box 3 regime was incompatible with the European Convention on Human Rights, due to its taxation based on deemed returns. Therefore, the long-term objective for Box 3 is to shift toward taxing actual returns. However, implementation has been postponed until 2028. In the meantime, the deemed return rate for “other” assets (such as shares and real estate) will be increased by explicitly taking into account rental income and the benefit of owner-occupation. As a result, the deemed return for this category will increase to 7.78%. The tax-free allowance will be reduced to € 51,396 per taxpayer. Assets will be valued at their economic value, and the vacancy value ratio (valuation method for rented residential property) will no longer apply in non-arm’s length transactions between affiliated parties.
The government also addresses the so-called bond loophole, where taxpayers exploit mismatches in valuation rules by purchasing bonds with accrued interest. To close this loophole, bonds must now be valued at fair market value, including accrued interest. The exemption for short-term claims will be abolished, except for bank deposits. These changes apply retroactively from 25 August 2025 at 16:00 CET, with transitional rules for assets held before that time.
Wage tax
6. Company car taxation
Since 2014, the additional tax liability (bijtelling) for private use of a company car has been gradually increased for electric vehicles. As of 2026, the favorable regime disappears entirely: the same 22% rate of the list price will apply to both new electric and new non-electric cars.
Starting in 2027, the government will impose a 52% pseudo-final levy on the private-use surcharge for non-zero-emission lease cars.
7. Clarification bicycle scheme
Employer-provided bicycles or bicycles made available to a self-employed individual enjoy favorable tax treatment. The bicycle scheme will be amended retroactively to 1 January 2020. If the bicycle is not stored at, or only incidentally stored near, the employee’s or entrepreneur’s place of residence, no wage tax or personal income tax will be due. This amendment applies to all types of bicycles, including shared bikes and hub-based bikes, and serves to clarify the application of the existing scheme.
8. Extending the RVU exemption
Starting in 2026, the temporary exemption for early retirement payments (RVU) will become permanent. The threshold amount will be increased by € 300 gross per month, indexed to the minimum wage. This means employers can offer employees early retirement (up to three years before retirement age) without facing the punitive 52% additional tax (pseudo-final levy) on payments up to this threshold. For payments above the threshold, the tax rate will gradually increase, reaching 65% by 2028. The scheme is specifically aimed at employees in physically demanding jobs
VAT
9. No increase in the VAT rate on culture, sports and media
Cultural, media and sports services will remain taxed under the reduced 9% VAT rate, following heavy debate and sector lobbying. However, VAT on accommodation services will rise to 21% as planned, with a transitional arrangement in 2026.
European tax law
10. Adjustments to the implementation of global minimum tax (Pillar 2)
The Dutch Minimum Tax Act 2024 (Wet minimumbelasting 2024) will be adjusted by incorporating the most recent OECD guidance to ensure consistent international application of the minimum tax rules under Pillar 2. In addition, joint ventures are now explicitly qualified as group entities.
Under the current temporary Qualified Jurisdictional Reporting Safe Harbour rule, no top-up tax is due for group entities located in a jurisdiction for specific reporting years, provided certain conditions are met. This rule offers administrative relief and simplifies compliance for multinational groups operating in qualifying jurisdictions.
The safe harbour rule is now refined by requiring corrections for hybrid intra-group payments and allowing separate financial statements for permanent establishments to qualify for safe harbour calculations.
Inheritance and gift tax
11. Gifts within 180 Days before death
As of 1 January 2026, gifts made within 180 days prior to a person’s death will be treated exclusively as part of the inheritance for tax purposes. This means they will no longer be subject to separate gift tax reporting or assessment. Instead, such gifts must be declared in the inheritance tax return and will be fully taxed under the inheritance regime. The measure applies retroactively to gifts made up to 180 days before 1 January 2026.
Energy
12. Industrial CO2 levy
Several adjustments to the Dutch industrial CO₂ levy are proposed. For nitrous oxide installations and installations falling in category 1 of the EU Emissions Trading System, the rate will drop to € 78.67 per ton in 2026, with free allowances expanded and then frozen. It is expected that many companies will face little or no costs up to 2030, especially as surplus allowances can be carried back to offset earlier payments. By contrast, waste incineration plants will face a stricter regime: the levy is increased to € 295 per ton by 2030, free emissions will be phased out by 2033, and trading of allowances with other sectors will be banned. Finally, the carry-back mechanism will be broadened, enabling companies to reclaim levy payments if they later reduce emissions more than expected.
Other
13. Distance-based air passenger tax
Effective 1 January 2027, the Dutch air passenger tax (vliegbelasting) will be reformed by introducing a distance-based rate structure. The current flat-rate tax per departing passenger will be replaced by a system in which the amount of tax depends on the final destination of the flight. Longer flights will be subject to a higher tax rate, reflecting their greater environmental impact.