2027 Tax Plan

Adjustment of the group concept for a qualifying membership right in a holding cooperative

There may be uncertainty as to whether there is a ‘qualifying membership right’ where several members of a holding cooperative form a cooperating group but those members are not affiliated with each other. The statutory wording may be interpreted as requiring an assessment of whether there is a ‘cooperating group’ in relation to a member, rather than whether there is a cooperating group in relation to the members of the holding cooperative. The latter is the legislator’s intention, and the group concept will be adjusted accordingly.

Dividend withholding tax refund scheme for Dutch underlying investors in foreign investment funds

A new refund scheme will be introduced for Dutch underlying investors who receive dividends from companies based in the Netherlands through foreign investment funds. When specific conditions are met, this refund scheme will let Dutch underlying investors reclaim the dividend withholding tax that the foreign investment fund has withheld.

Support for startups and scale-ups

A reduction in the taxable base has been proposed for share options granted to employees of startups and scale-ups. Under this measure, only 65 per cent of the taxable benefit would be treated as employment income. This directly lowers the tax burden and makes employee participation a more attractive and competitive form of remuneration.

Read more in our Tax News article ‘Consultation on draft legislative proposal for tax incentives for startups’.

Legal presumption based on hourly rate for self-employed workers

A new labour-law presumption of employment is introduced. Self-employed workers who charge below a set hourly rate (indicatively 38 euro in 2026) will be able to rely on this presumption. When a self-employed worker uses this presumption, the client will need to show that no employment contract exists.

Pseudo-final levy on private use of fossil-fuel company cars*

Employers must pay a 12% pseudo-final levy on the list price of a company car when an employee has a fossil-fuel company car, meaning a car that isn’t fully emission-free, and uses that car for private purposes. This applies even if the employee contributes to the costs.

For cars made available before 2027, transitional rules will apply until 17 September 2030, with a possible extension to 1 January 2031. There are also expected exemptions for temporary replacement cars and driving-school cars, along with an anti-accumulation rule for the final levy on excessive severance payments.

Reduction of the expat scheme to 27%*

The maximum tax-free fixed allowance under the expat scheme will be reduced to 27%. Transitional rules will apply for expats who were already using the expat scheme before 2024. In addition, a higher salary threshold will apply for employees who do not fall under the transitional rules.

Determination of acquisition price upon relocation of corporate seat to NL

When foreign tax liability arises, particularly due to the relocation of a company's corporate seat to the Netherlands, the fair market value of the substantial interest will serve as the starting point. As a result, only an increase or decrease in value after the relocation of the corporate seat will fall under the box 2 levy in the Netherlands.

Proposed improvements to future box 3 system

On Budget Day, the State Secretary will present a proposal for improvements to the legislative proposal for the Actual Return Box 3 Act by means of a novelle (amending bill). These include, for example, the introduction of one year of loss carryback, a rollover scheme for marriage in community of property and divorce in the case of real estate and shares in start-up businesses, the reduction of the rate from 36 to 35 percent and the increase of the tax-free result from 1,800 to 1,900 euros, as well as the further development of the system towards a capital gains tax. The new box 3 system is set to take effect on 1 January 2028.

New definition of startup and scale-up*

Because the definition of start-ups and scale-ups in the legislative proposal for the Actual Return Box 3 Act (entry into force 2028) does not adequately align with the specific characteristics of these businesses, a new definition will already apply as of 1 January 2027. A start-up or scale-up is a business focused on rapid growth through a scalable and repeatable revenue model that originates from innovation. The shares may not be traded on a regulated market and may not be held, directly or indirectly, for more than 25 percent by a listed entity.

Read more in our Tax News article ‘Consultation on legislative proposal for tax incentives for startups’.  

Revision of the zero VAT rate for warships

The legislative amendment clarifies the current statutory text to ensure in practice that supplies of goods to, and maintenance of, warships fall within the 0% VAT rate.

Air passenger tax: rate differentiation from 2027*

Three rates will be introduced for air passenger tax. The rate will be EUR 29.40 for short-haul flights, EUR 47.24 for medium-haul flights, and EUR 70.86 for long-haul flights. The rates will still be adjusted for inflation.

Industrial CO2 levy: no dispensation rights for renewable hydrogen

No dispensation rights (DPRs) will be granted within the industrial CO2 levy for the production of renewable hydrogen. A separate policy instrument has been developed for renewable hydrogen production. Granting additional DPRs could disrupt the existing and forthcoming hydrogen policy instruments.  

Real estate transfer tax rate

The general real estate transfer tax rate for the acquisition of homes that the buyer will not occupy personally (such as rental homes or holiday homes) will be reduced from 8 per cent to 7 per cent.