Main tax measures of the 2027 Tax Plan for international organisations
The measures will apply from 2027, unless stated otherwise. The measures marked with a * have already been included in a previous legislative proposal.
Corporate income tax
Interest deduction limitation for housing corporations abolished
From 2028, housing corporations will be fully exempt from the earnings-stripping interest deduction limitation rule (an ATAD measure), meaning that the full net interest balance will be deductible each year, subject to any other limitations. The current system will continue to apply to the interest balance carried forward that arose in financial years commencing before 1 January 2028. The intended effect is to increase the investment capacity of housing corporations. This measure will be added to the Bill at a later stage, at which point the details will also be announced.
Bill introducing safe harbour rules into the Minimum Taxation Act 2024
The proposal implements the Pillar Two Side-by-Side Package, which was agreed by the OECD/G20 Inclusive Framework on BEPS on 5 January 2026.
The legislative proposal introduces four new Safe Harbours:
- the Simplified Effective Tax Rate (ETR) Safe Harbour, for fiscal years commencing on or after 31 December 2025;
- the Side-by-Side Safe Harbour;
- the Ultimate Parent Entity (UPE) Safe Harbour; and
- the Substance-based Tax Incentives Safe Harbour.
In addition, the proposal provides for an extension of the existing temporary Qualified Country-by-Country Report Safe Harbour (also referred to as the “CbCR Safe Harbour”). As a result, it may continue to be applied to fiscal years beginning on or before 31 December 2027 and ending before 1 July 2029.
The Simplified ETR Safe Harbour applies retroactively with effect from 31 December 2025. The other three new Safe Harbours and the extension of the Transitional CbCR Safe Harbour apply retroactively with effect from 1 January 2026.
Expansion of the fixed-rate scheme in the innovation box
Since 2013, taxpayers have been able to opt to determine on a fixed-rate basis the benefits attributable to the innovation box. The maximum fixed-rate amount of qualifying benefits is increased from 25,000 euros to 100,000 euros. Under this scheme, companies may designate 25 per cent of their profits as qualifying benefits in the innovation box, which are then taxed at an effective CIT rate of 9 per cent.
Tax treatment of foreign exchange results on hedging instruments under the participation exemption
"Non-priced" (i.e. non-predictable) foreign exchange results may, upon request, qualify for the participation exemption, provided that the tax inspector has confirmed that the relevant legal transaction serves to hedge a foreign exchange risk relating to the participation. However, the participation exemption will no longer be available, even upon request, for "priced" foreign exchange results, that is, foreign exchange results that are expected because they are attributable to the strength or weakness of the relevant currency. In addition, taxpayers will be able to elect to discontinue the application of the participation exemption to a hedging instrument from a chosen point in time. Transitional rules will apply to existing instruments, provided that a ruling has been issued before 15 September 2026.
This measure is intended to cover the loss of tax revenue resulting from the Dutch Supreme Court’s judgment of 21 March 2025 on the application of the liquidation loss regime.
Abolition of the non-business purpose presumption in the business merger and demerger facilities
In a judgment dated 27 February 2026, the Dutch Supreme Court held that the presumption of non-business motives in the demerger relief is not compatible with the EU Merger Directive. To remedy this incompatibility, this presumption will be removed from both the demerger relief and the business merger relief. As a result of this amendment, the possibility of obtaining advance certainty will disappear.
Increase of the deduction percentage of the EIA
The deduction percentage for the energy investment allowance (EIA) will be increased from 40 per cent to 45.5 per cent.
Adjustment to the debt waiver profit exemption*
For the purposes of the debt waiver profit exemption, a reduction in debts resulting from the exercise of a write-down power by DNB or a comparable institution will, under certain circumstances, be treated in the same way as the relinquishment of rights that cannot be realised. This means that, in such a situation, the debt waiver profit exemption may be claimed (which is currently not possible).
Abolition of the forestry exemption
The forestry exemption, which exempts profits from forestry businesses from income tax and corporate income tax, will be abolished from 1 January 2029. There will be no transitional provisions. The scheme was evaluated negatively in terms of effectiveness and efficiency. Five million euros of the proceeds will be allocated through the budget to nature policy.
Dividend withholding tax
Refund scheme for Dutch underlying investors in foreign investment funds
A refund scheme will be introduced for Dutch beneficiaries (both legal entities and individuals) who receive dividends originating from companies established in the Netherlands through foreign investment funds. Under this refund scheme, Dutch beneficiaries may, subject to conditions, reclaim the dividend tax withheld at the expense of the foreign investment fund.
Wage tax
Support for startups and scale-ups
A reduction of the tax base has been proposed for share options granted to employees of startups and scale-ups. As a result, only 65 per cent of the taxable benefit is taxed as employment income. This reduces the effective tax burden to approximately 32 per cent. In addition, the taxable event will be shifted to the moment the shares or share options are sold. This will make employee equity participation a more attractive form of remuneration.
Read our Tax News article on this subject later.
Pseudo-final levy on private use of fossil-fuel company cars
From 2027, employers will have to pay a pseudo-final levy of 12 per cent of the catalogue value of the company car for employees who have a fossil-fuel company car (not fully emissions-free) made available to them and also use it for private purposes. The transitional rules for cars made available before 1 January 2027 will be extended until and including 31 December 2030. It is also proposed to remove a number of bottlenecks in the scheme, including exemptions for temporary replacement cars (maximum 14 days per maintenance or repair period), manual-transmission driving-school cars and certain short-term rental cars made available. An anti-cumulation provision will also be introduced to prevent overlap with the pseudo-final levy on excessive termination payments.
Read our Tax News article on this subject here.
Reduction of the expat scheme to 27%*
The maximum tax-free fixed allowance under the expat scheme will be 27%. Transitional rules will apply to expats who were already using the expat scheme before 2024. In addition, a higher salary threshold will apply to employees who are not covered by the transitional rules.
Read our Tax News article on this subject.
Legal presumption of employee status for self-employed persons*
A legal presumption of employee status will be introduced: self-employed persons working for an hourly rate below a certain threshold (indicatively €38 in 2026) may rely on this legal presumption. If self-employed persons rely on the legal presumption, their clients must demonstrate that there is no contract of employment. This legislation will enter into force on 31 December 2026.
Personal income tax
Increase in the first and second personal income tax brackets
The rate in the first income tax bracket increases by 0.48 percentage points to 36.23 per cent and in the second bracket by 0.6 percentage points to 38.16 per cent. This compensates for the lower healthcare insurance premiums. The threshold amount for the highest rate remains unchanged.
Determination of acquisition price upon relocation of corporate seat to the Netherlands
When a shareholder with a substantial interest becomes subject to non-resident taxpayer status as a result of a company relocating its corporate seat to the Netherlands, the fair market value of the substantial interest will serve as the starting point. Consequently, only an increase or decrease in value after the relocation of the corporate seat will be subject to Box 2 tax in the Netherlands. This measure does not apply if the taxpayer was previously subject to non-resident taxpayer status in respect of the substantial interest.
Deferral of amendments to the new Box 3 regime until the 2027 Spring Memorandum
On Budget Day, the government did not submit an amendment bill to the Actual Return Box 3 Bill, because funding for mitigating measures is lacking. The government is postponing a decision on amendments to the bill or on a new bill concerning the future Box 3 system until the 2027 Spring Memorandum. The bill will probably remain pending in the Senate. This means that its implementation in 2028 is under pressure. Introducing a full capital gains tax in Box 3 could be possible by 2030 with an ambitious legislative timetable.
For further details, see our Tax News Alert.
New definition of startup and scale-up
Because the definition of a startup in the bill for the Actual Return Box 3 Bill (intended to enter into force in 2028) does not sufficiently reflect the specific characteristics of startups and scale-ups with a share option scheme, a new definition for startups and scale-ups will apply from 1 January 2027. A startup or scale-up is a withholding agent carrying on a business aimed at rapid growth through a scalable and repeatable business model originating from innovation. The shares must not be traded on a regulated market and must not be held, directly or indirectly, for more than 25 per cent by a listed entity.
VAT and excise duties
VAT rate for ornamental horticulture increased from 2028
As of 1 January 2028, ornamental horticulture products will be subject to the standard 21 per cent instead of the reduced 9 per cent rate. This includes, among other things, cut flowers, indoor and outdoor plants, flower bulbs, and nursery products such as Christmas trees.
VAT rate for hot-air balloon flights increased
From 1 January 2028, the standard VAT rate of 21 per cent will apply to hot-air balloon flights instead of the reduced rate of 9 per cent. Under the transitional provisions, the VAT rate applicable at the time of the balloon flight will be decisive, including where payment was made in advance or a voucher was purchased earlier.
Expansion of the one-stop shop scheme*
As part of the first ViDA pillar, the one-stop shop scheme will be expanded to include, among other things, cross-border supplies of gas, electricity, heating and cooling. The call-off stock arrangement will be phased out and replaced by the new transfer arrangement as of 1 July 2028.
Clarification on the application of the zero VAT rate for warships
The amendment removes an ambiguity and confirms current practice regarding the application of the 0 per cent rate to the supply, hiring out, repair and maintenance of warships.
Excise duty on alcohol increased
The government is introducing an indexation method for excise duty on alcohol and alcoholic drinks. The excise duty rates will be adjusted annually for inflation (based on the so-called table adjustment factor). It is not yet known what this will mean in concrete terms from 2027 onwards.
Fuel excise duty reduction extended
In 2022, the government reduced the excise duty rates on petrol, diesel and LPG because of rising energy prices. The government is extending the excise duty reduction. Excise duty remains at 85 cents per litre of petrol and 55 cents per litre of diesel. Following the expiry of the temporary excise duty reductions, the government will reassess their cross-border effects in 2028.
Excise duty refund scheme for biofuels abolished
The excise duty refund scheme for motor fuels consisting wholly or partly of biofuels or other renewable fuels is abolished.
Temporary reduction of petrol excise duty on the BES islands
In 2027, the excise duty on petrol in the BES islands will also be temporarily reduced: by 5.5 US cents per litre on Bonaire, and by 4.19 US cents per litre on Sint Eustatius and Saba.
Reduced excise duty rate for small breweries abolished
The government will abolish the reduced excise duty rate for small breweries from 2028. As a result, beer excise duty will become simpler, clearer and easier to enforce.
Climate, energy and automotive
Increase of the deduction percentage of the EIA
The deduction percentage for the energy investment allowance (EIA) will be increased from 40 per cent to 45.5 per cent.
Fuel excise duty reduction extended
In 2022, the government reduced the excise duty rates on petrol, diesel and LPG because of rising energy prices. The government is extending the excise duty reduction. Excise duty remains at 85 cents per litre of petrol and 55 cents per litre of diesel. Following the expiry of the temporary excise duty reductions, the government will reassess their cross-border effects in 2028.
Excise duty refund scheme for biofuels abolished
The excise duty refund scheme for motor fuels consisting wholly or partly of biofuels or other renewable fuels is abolished.
Tax on tap water (BoL): rate increased by 10 cents
In 2027, the rate on water of drinking water quality will be increased by 10 eurocents per 1,000 litres (cubic metre). Including indexation, the rate in 2027 will therefore be 0.551 eurocents per 1,000 litres (excluding VAT).
Tax on tap water (BoL): levy ceiling abolished and limitation of the tax to drinking-quality water*
The BoL levy ceiling will be abolished. BoL will only be levied on the consumption of drinking-quality water. No tax will therefore be due on the consumption of water that is not drinking water, such as surface water used for cooling.
Temporary reduction in the heavy goods vehicle charge
A temporary rate reduction of 22.3 per cent applies retroactively to the heavy goods vehicle charge for the period from 1 September 2026 to 31 December 2026.
Air passenger tax: rate differentiation
There will be three rates of air passenger tax, differentiated according to the passenger’s final destination. In addition to indexation of the rates, a lower top rate is proposed. The rate for short-haul distances will be 31.04 euros, for medium-haul distances 49.87 euros and for long-haul distances 59.43 euros.
Final destination for air passenger tax can also be demonstrated with a flight plan
From 1 January 2027, the rate of air passenger tax will depend on the passenger’s final destination. If there is no contract of carriage, for example in the case of private flights in the passenger’s own aircraft, the final destination may be demonstrated using the flight plan.
Other
Reduced real estate transfer tax rate for residential properties
The government will reduce the real estate transfer tax rate from 8 per cent to 7 per cent for the acquisition of residential properties that the purchaser will not use as their primary residence, such as rental properties or holiday homes.
This content was generated with the assistance of AI.
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Tax rates 2027/2026
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