Expectations Tax Plan package 2027
The 2027 Tax Plan package builds on earlier policy choices, tackles technical issues, and responds to recent case law. It consists of four bills: the 2027 Tax Plan, the 2027 Other Fiscal Measures Act, the Safe Harbour Rules Minimum Tax Act 2024, and the Tax Incentives for Startups and Scale-ups Act.
Most measures are set to apply from 1 January 2027. Some measures follow a different timeline. For example, the new Box 3 regime based on actual return is due to take effect on 1 January 2028. We expect an amendment to the draft Box 3 Actual Return Act to be announced on Budget Day.
Which topics are expected?
At a high level, the package is expected to affect a wide range of taxes. The following themes are likely to be included:
- Corporate income tax, including amendments in response to recent Supreme Court rulings, such as the treatment of foreign exchange results under the participation exemption and the removal of the presumption of non-business motives in the legal merger and demerger facility.
- Payroll tax and personal income tax, including measures to support startups and scale-ups, a higher rate in the first and second brackets of Box 1, the freedom contribution, and proposals to improve Box 3.
- VAT and excise duties, including changes to the consumption tax on non-alcoholic beverages.
- Gift and inheritance tax, including measures to address paper gifts.
- Climate and energy measures, such as the discontinuation of dispensation rights (DPRs) for the production of renewable hydrogen.
- Other measures, including the transfer tax rate and changes to legal protection in disputes relating to deferral of payment and remission of tax debts.
These themes are expected to form the core of the tax agenda for the coming year. The detailed design and scope of each proposed measure will only become clear on Budget Day.
Parliamentary process in a politically uncertain context
The outcome of the government’s proposals remains uncertain. During the parliamentary process, proposals may change or be withdrawn. This is especially relevant because the government is operating as a minority cabinet and will need additional support in both the House of Representatives and the Senate to pass its plans.
That means measures may still be added, removed or amended, even after the bills are presented on Budget Day. We follow the developments closely and constantly update our overview and related analyses.
See the full overview on our Expectations page
Would you like to see which specific measures we expect for each type of tax and what they could mean for you or your organisation? You can visit our Expectations page, where we set out the expected tax measures by tax type, alongside related in-depth articles. We update this page whenever new information becomes available.
If you have any questions about the impact of the expected measures on your situation, please contact your PwC tax adviser.
