2026 Tax Plan

Equal treatment of biological and legal children

Biological and legal children will be treated equally in terms of gifts and inheritances, ensuring that biological children are also entitled to the child exemption and the lower tax rate.

Adjustment of marital property division upon death

If the surviving spouse receives more than half of the assets upon dissolution of a community of property with an unequal distribution or through the application of a settlement clause, gift or inheritance tax will still need to be paid on the additional part that exceeds half. This is to prevent the modification of marital conditions shortly before the death of one partner to allocate more assets to the surviving spouse and thus save on inheritance tax. This should have retroactive effect up to and including 18 April 2025, the date of the announcement.

Act clarifying assessment of employment relationships

The DBA Act will be replaced by the Act Clarifying Assessment of Employment Relationships (Wet VBAR). This new law codifies recent jurisprudence and introduces additional measures, such as a legal presumption of employment under labor law for self-employed individuals earning less than approximately 36 euros per hour.

Employee stock options for startups and scale-ups

From 2027, a new tax scheme will be introduced to stimulate employee participation in startups and scale-ups. This scheme defers taxation until the actual sale of stock options. Moreover, the maximum tax rate on income from stock options will be reduced from 49.5 percent to 32.17 percent. This is achieved by considering only 65 percent of the value of the stock options as the taxable base.

Pseudo-final levy on private use of fossil fuel cars

From 2027, withholding agents must pay a pseudo-final levy of 52 percent on the basis for the addition for private use of company cars for employees who have a fossil fuel (not fully emission-free) company car at their disposal. This also applies if the employee contributes to the costs themselves.

Introduction of an admission system for temporary employment agencies (lenders)

An admission system will be introduced whereby temporary employment agencies can only operate with official admission, based on the NEN-4400 standard. This should ensure more reliability and quality in the sector.

Public register for registration as a lender

A presumption will be introduced that a company registered in the public register is a lender, which means that fiscal liability for hirers could apply. This aims to make it easier to avoid misunderstandings regarding the legal status of hirers and contractors.

Simplified liability for hirers

Companies that hire employees through temporary employment agencies can be held liable for tax payments more quickly by using a standard percentage of 35 percent of the invoice amount as a starting point. If less than this percentage is deposited into a g-account, liability can be established more quickly.

No VAT increase on culture, sports and media

The proposed VAT increase on culture, sports and media as of 1 January 2026, has been canceled. The reduced VAT rate will therefore remain in place. The transitional arrangement is no longer relevant for these categories and has been adjusted accordingly.

VAT increase on accommodation

The reduced VAT rate (9 percent) will be abolished for the provision of accommodation (short stays within the framework of hotel, boarding house, and holiday spending businesses). From 1 January 2026, these provisions will legally fall under the general VAT rate (21 percent). The transitional arrangement aims to subject overnight stays in 2026 to the 21 percent rate, even if the reservation and payment are made in 2025.

Introduction of VAT deduction revision*

From 1 January 2026, a deduction revision will apply to certain services related to immovable property ('immovable investment services'). This means that the VAT deducted on such services must be adjusted if the use of an investment good changes during a period of five years. This revision scheme only applies to immovable investment services with a value of at least 30,000 euros.

Cancellation of excise duty increase on alcohol

The previously planned increase in tax on alcoholic beverages will not go ahead.

Consumption tax on non-alcoholic beverages

From 2027, the current exception to the consumption tax on lemonade will be restricted. The definition of lemonade proved to be too limited, as fruit juices with 'a touch of dairy' fell outside the scope of the tax. The new exception to the tax will only apply to the 'purest dairy and soy drinks'. Lemonades with just a small amount of dairy will then be taxed.

Increase in the MIA budget reserve

The Environmental Investment Deduction (MIA) is a tax scheme that encourages entrepreneurs to make environmentally friendly investments. The budget for this scheme will be increased by 35 million euros. This extra budget is financed by a reduction in the VAMIL reserve, another environment-related scheme that has not been fully utilized in recent years.

Second law amendments to the Minimum Tax Act 2024

The Minimum Tax Act 2024, also known as Pillar Two, provides for a minimum effective tax rate of 15 percent per jurisdiction for large international companies (annual turnover exceeding 750 million euros). This bill will incorporate elements from the administrative guidelines. In addition, some technical changes will be made.

Implementation of EU Directive DAC9

This implements a European directive (DAC9) that improves the exchange of information related to Pillar Two between tax authorities in the EU. Part of this is a simplified procedure for submitting a 'Top-up tax information return'.

Open standard 'appropriate equity' for conduit companies art. 8c CIT

An open standard will be introduced for conduit companies as referred to in art. 8c CIT. This will abandon the equity requirement for conduit companies. This requirement currently functions as a safe harbour.

CO2 levy rate for industry

Dutch ETS companies/installations must pay a levy of 21.14 euros (2025) for each ton of CO₂ for which no dispensation right (DPR) has been surrendered. From April 2026, transfer of dispensation rights between installations will be possible, after which tax returns for 2025 must be filed on 1 October 2026.

Bill for implementation of Carbon Border Adjustment Mechanism (CBAM)

By 2026, the transition phase of CBAM will be completed and CBAM will be fully operational. CBAM is designed to promote fairer competition and prevent carbon leakage by introducing a carbon price on imported goods. This should prevent companies from moving their production to countries with less stringent environmental regulations.

Reduced energy tax rate for hydrogen*

An energy tax rate will be introduced for the energetic use of pure hydrogen. The rate is equal to the electricity rate in the fifth bracket (and lower than the rate for natural gas). Grey, blue, and green hydrogen will be taxed equally.

Differentiation of flight tax

The tax on flying will be adjusted from 2027, likely by introducing different rates depending on factors such as the distance or environmental impact of the flight.

Plastic levy

The plastic levy that would have been imposed on companies from 2028 will not go ahead.

Expansion of starter's exemption for transfer tax

The starter's exemption in transfer tax will be increased to 555,000 euros for home buyers between 18 and 35 years old who are buying a home for the first time to live in themselves.

Introduction of specific general housing rate of 8 percent for transfer tax

A specific general housing rate of 8 percent will be introduced in the transfer tax. This rate applies to homes that do not meet the main residence requirement, such as holiday homes or second homes. For non-residential properties (such as commercial buildings), the general rate of 10.4 percent will continue to apply. For homes that serve as a main residence, the reduced rate of 2 percent will remain in effect.

Deferment of payment without collection of interest

When silently converting an income tax enterprise into a private or public limited company, it will become possible to obtain a deferment of tax payment without additional interest being calculated.

DAC8: automatic exchange of information on crypto transactions

DAC8 is an EU legislative proposal aimed at improving transparency around crypto-assets, or digital currencies and assets such as Bitcoin. DAC8 requires service providers involved in crypto transactions to automatically exchange information about these transactions.