Main tax measures of the 2026 Tax Plan for international organisations

Wage tax

Curtailment of the expatriate cost reimbursement regime

The extraterritorial costs regime (ETK regime) will be curtailed. As of 2026, expenses related to cost of living, such as gas, water, electricity, and private calls to the home country, can no longer be reimbursed tax-free. This amendment is intended to ensure that only reimbursements directly related to the employment relationship remain eligible for the regime.

Employee share options for startups and scale-ups

In the Spring Budget Memorandum, a new tax regime was introduced to encourage employee participation in startups and scale-ups. Under this regime, taxation on share options is deferred until the moment the shares are actually sold.

Additionally, the maximum tax rate on income from share options will be reduced from 49.5 per cent to 32.17 per cent, as the taxable base will be narrowed to 65 per cent of the income derived from the share options.

This regime is not included in the Tax Plan but is mentioned due to potential overlap with the lucrative interest regime. For share options that fall under both regimes, it is being considered not to apply the lower tax burden of the startup regime. This will be further examined during the detailed development of the startup regime.

Value-added tax and excise duty

Extension of reduced VAT rate to radiopharmaceuticals*

The reduced VAT rate of 9 per cent will also apply to radiopharmaceuticals. This amendment corrects a previous omission and ensures equal tax treatment with other medicinal products.

Extension of excise duty reduction

The reduction in excise duties on fuel will be extended by one year, until the end of 2026. In 2022, the Dutch government reduced excise rates on petrol, diesel, and LPG in response to rising energy prices. Without intervention, this reduction would have expired at the end of this year.  

On 27 August, the House of Representatives adopted a motion requesting that the anticipated increase in petrol prices as of 1 January be neutralised. This request has been addressed in the Tax Plan.

Limitation of excise duty refund to RFNBOs*

The regime for excise duty refunds on motor fuels that consist wholly or partly of renewable fuel is being amended. Going forward, it will apply exclusively to renewable fuels of non-biological origin (RFNBOs). This adjustment follows from the implementation of provisions in the EU amending directive on renewable energy (RED III) that relate to the transport sector.

Corporate income tax and Minimum Tax

Liquidation loss regime

Following a ruling by the Supreme Court on the liquidation loss regime, a budgetary loss in corporate income tax is expected. According to the Budget Memorandum, this loss will be partially offset by adjusting the tax treatment of profits on hedging instruments for currency risks. This measure will first be offered for public consultation, with a proposed effective date of 1 January 2027.

Temporary transitional law for Mutual Funds (FGR)

An investigation is underway into the potential issue that some partnerships may qualify as a mutual fund (in Dutch: fonds voor gemene rekening, FGR) as of 1 January 2025, and thus the partnership itself becomes taxable. This may lead to a revision of the FGR definition. As a result, funds that qualify as an FGR from 2025 may no longer be considered as such starting in 2027.

To prevent short-term tax liability (i.e., for 2025 and 2026), a transitional measure is proposed. This allows entities that were considered fiscally transparent through 2024 to opt out of being classified as an FGR starting on 1 January 2025.

Entities can opt into this transitional regime until 28 February 2026. The transitional regime will expire on 1 January 2028. If the FGR definition is amended effective from 1 January 2027, the transitional regime will expire at that time.

Adjustment to minimum capital rule in corporate income tax

The minimum capital rule is a specific interest deduction limitation for banks and insurers. The exception for internal liquidity management under this rule was unintentionally broad and is now being narrowed. Loans directly related to loans obtained from natural persons will no longer fall under the internal liquidity management exception. This means that interest on these loans will now be subject to the minimum capital rule.

Aggregation rule for maximum investment amount in Energy Investment Deduction

An aggregation rule is proposed for the Energy Investment Deduction (EIA), whereby a maximum total of 151 million euros (2025 amount) in energy investments per taxpayer per year will be eligible. This cap includes energy investments in the taxpayer’s own business and in businesses that are part of a partnership.

Interaction between work-related costs regime and deduction limitation for mixed expenses*

Currently, the determination of the non-deductible portion of mixed expenses is based on the wage definition from wage tax law. However, since the introduction of the work-related costs regime, this has become complex and has unintentionally broadened the base for the deduction limitation. To correct this, it is proposed to base the calculation on the wages actually subject to wage tax for the relevant employees.

Open norm for 'Adequate Equity Capital' in conduit companies – Article 8c CIT

It was previously announced that an open norm will be introduced for conduit companies as referred to in Article 8c of the Corporate Income Tax Act. This measure is expected to be published in a separate memorandum following the Budget Day. With this open norm, the current equity requirement for conduit companies—currently functioning as a safe harbour—will be abolished.

Adjustment to objection possibility for uncredited corporate income tax*

It will be stipulated that an objection can only be filed once regarding uncredited corporate income tax related to the participation exemption, the crediting of foreign business profits, and the crediting of benefits from a controlled entity (relevant in cases of carryforward over multiple years). A taxpayer may only object to such a decision in the year in which the decision was first issued.

Second amendment to the Minimum Tax Act 2024

The Minimum Tax Act 2024 (Pillar Two) introduces, as of 31 December 2023, a minimum effective corporate tax rate of 15 per cent per jurisdiction for large multinational enterprises (annual turnover exceeding 750 million euros).

This amendment includes several technical changes and incorporates remaining elements from the administrative guidance of the Inclusive Framework on Base Erosion and Profit Shifting (BEPS).

The legislative proposal primarily addresses the following topics:

• Transparent and hybrid entities (definitions, profit attribution);
• Joint ventures and related parties as group entities;
• Different financial years for non-consolidated group entities;
• Book values differing from those under financial reporting standards;
• Deferred tax assets arising before the transition year due to arrangements with a government authority or the introduction of a corporate tax;
• The temporary safe harbour rule based on a qualifying country-by-country report.

These measures will enter into force on 31 December 2025, with some provisions having material retroactive effect to 31 December 2023. Also read our Tax News article 'Pillar Two 2026 Tax Plan'.

EU Directive DAC9 – Pillar Two

The EU Directive DAC9 will be implemented. This Directive facilitates the exchange of Pillar Two-related information between tax authorities within the EU. It includes a simplified procedure for submitting a ‘Top-up Tax Information Return’ at a central level for the entire multinational group using a standardised template. Read more on this topic in our Tax News article 'Dutch legislation to implement DAC9'.

Climate, energy and car

Rate for CO₂ levy on industry

For the period 2026–2030, the rate for ETS1 and nitrous oxide installations will be reduced to 78.67 euro per tonne of CO₂, and the dispensation factor will be adjusted to 1.023.

Since this national CO₂ levy for ETS1 and nitrous oxide installations is only payable when the rate exceeds the EU ETS price, and the expectation is that the EU ETS price will be higher than 78.67 euro per tonne of CO₂ from 2027 onwards, no CO₂ levy would be due from that point.The EU ETS price depends on many factors. Additionally, it is intended that parties aligned with the European ETS sustainability goals will already be effectively exempt from the national CO₂ levy starting in 2026.

Rate for CO₂ levy on waste processing installations

For the period 2026–2030, the rate for waste processing installations will be increased to 295 euro per tonne of CO₂. The dispensation factor will be rapidly reduced to zero by 2033. With this price and dispensation factor, the Dutch government aims to strengthen the business case for CO₂ capture and storage by waste processing installations.

Carry-back of CO₂ tax dispensation rights

The facility for offsetting dispensation rights will be adjusted and will no longer be subject to a time limit. Additionally, the requirement to offset them against the oldest outstanding year has been abolished, allowing parties to choose the most financially favourable settlement.

Draft bill for implementation of Carbon Border Adjustment Mechanism (CBAM)

From 2026, the transition phase of CBAM will be completed and the mechanism will be fully operational. To facilitate this, the Environmental Management Act will include various implementation-focused measures.

Waste tax

Starting in 2028, tax rates on the landfilling, incineration, and transfer of waste will be raised. This measure is intended to cover an annual budgetary gap of 567 million euros, which arises from the decision not to introduce a polymer levy. As of 2027, the tax exemption for the incineration of sewage sludge will be discontinued.

Extension of fuel excise duty reduction

The reduction in excise duty on fuel will be extended by one year, until the end of 2026. In 2022, the Dutch government lowered excise rates for petrol, diesel, and LPG due to rising energy prices. Without intervention, the discount would expire at the end of this year. On 27 August, the House of Representatives adopted a motion requesting that the price increase for petrol from 1 January be offset, which has been addressed in the Tax Plan.

Limitation of excise duty refund to RFNBOs*

The excise duty refund scheme for motor fuels that are wholly or partly made from renewable fuel will be amended to apply exclusively to renewable fuel of non-biological origin (RFNBO). This change follows the implementation of provisions from the EU Renewable Energy Directive (RED III) relating to the transport sector.

Lorry charge*

From mid-2026, owners of lorries in the Netherlands will pay an average of 0.186 euro per kilometre driven. This charge applies to domestic and foreign lorries weighing 3,500 kilograms or more. It will be levied on motorways, and selected national and municipal roads. The Eurovignette will be abolished, and motor vehicle tax will be reduced.

Motor vehicle tax discount for passenger cars

From 2026 to 2028, zero-emission passenger cars will benefit from a 30 per cent discount on motor vehicle tax. From 2029, the discount will be 25 per cent.

Differentiated air travel tax

From 2027, the air travel tax will be adjusted by introducing tiered rates based on the distance and environmental impact of the flight. The tax will be 29.40 euro for destinations between 0–2,000 km, 47.24 euro for destinations between 2,000–5,500 km, 70.86 euro for destinations over 5,500 km or where the final destination cannot be determined. 

Reduction in energy tax

The general energy tax reduction per independent connection with a residential function will follow an adjusted price path in the coming years. A positive correction of 9.30 euro compared to the base price path will result in a lower energy bill.

Reduced energy tax rate for hydrogen* 

As of 1 January 2026, an energy tax rate for the energetic use of pure hydrogen will be introduced. The rate will be 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.  

Extension of electricity exemption used in electrolytic processes* 

The energy tax exemption for electricity used in electrolytic processes will be specified and expanded. The exemption will apply to electricity directly used in the demineralisation or electrolysis of water and the purification and compression of the hydrogen obtained from it.

Tax on mains water

The definition of mains water will be broadened to include ‘water of drinking water quality’. The tax ceiling will be increased from 300 cubic metres to 50,000 cubic metres in 2026, and small water suppliers (fewer than 1,000 connections) will also become liable for tax.

Abolition of plastic tax

The plastic tax (polymer levy) that companies were expected to face from 2028 will not be implemented.

Aggregation rule for maximum investment amount in Energy Investment Deduction

An aggregation rule is proposed for the Energy Investment Deduction (EIA), whereby a maximum total of 151 million euros (2025 amount) in energy investments per taxpayer per year will be eligible. This cap includes energy investments in the taxpayer’s own business and in businesses that are part of a partnership.

Subsidies and incentives

The government allocates 150 million euros to extend the Indirect Cost Compensation ETS Subsidy Scheme until 2028. Also, 230 million euros will be invested in upcoming IPCEI schemes, focusing on the semiconductor sector. The SDE scheme on the other hand will be reduced to 8 billion euros next year, partly due to insufficient uptake.

Other

DAC8: automatic exchange of information on crypto transactions*

The International Assistance in Tax Matters Act and the General State Taxes Act are being amended to implement EU legislation aimed at enhancing transparency around crypto-assets, such as Bitcoin (DAC8). Crypto service providers will be required to collect, verify, and share user data with the Dutch tax authorities.