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Tax measures announced in the 2025 Spring Memorandum

On 18 April 2025, the Dutch government presented their Spring Memorandum. Remarkably, the announced increase in VAT on culture, media and sports will be cancelled. The corresponding loss in revenue will be offset by a limitation of inflation adjustment in income tax.

Introduction

On 18 April 2025, the Dutch government presented their 2025 Spring Memorandum, informing parliament about the state of the central government’s finances. The Spring Memorandum also reported a number of tax measures, which are summarised below.

No increase in VAT rate on culture, media and sports
The increase in the VAT rate on culture, media and sports from 9% to 21% announced in the 2025 Tax Plan will definitely not go ahead. Financial coverage for this measure (around EUR 1.3b) has been found in limiting the inflation adjustment in income tax (see below).

Limitation of adjustment factor
In 2026, only 46.2% of the adjustment factor (tabelcorrectiefactor) in income tax will be applied. This means that in 2026, less than half of inflation will be offset by an increase in income tax brackets and income tax credits.

Startups and scale-ups
A special scheme will be introduced in wage tax that narrows the tax base of income from stock options for employees of startups and scale-ups to 65% and extends to the box 1 income tax. This makes the effective tax rate similar to a situation where stock options would have been taxed in box 2.  

Business discontinuation relief and co-working partner’s relief abolished
The business discontinuation relief in income tax will be reduced by 75% from 2027 onwards, down to an amount of EUR 908 (2025: EUR 3,630). In 2030, the entire scheme will be abolished. An evaluation showing the scheme no longer to serve a legitimate purpose inspired the legislator to abolish it. The co-working partner’s relief in income tax is being phased out for the same reason. First, the relief rates will be greatly reduced in 2027, after which the entire scheme will be terminated in 2030. The proceeds will be used to finance the new tax scheme for startups and scale-ups.     

New box 3 regime delayed
The introduction of the new box 3 regime, in which taxation is based on the actual return achieved, will be delayed to 2028. On top of that, owner-occupiers’ use of their own property can only be taken into account in the box 3 rebuttal scheme from 2026 onwards. The budgetary loss will be absorbed by increasing the flat rate for other assets in box 3 by 1.78 percentage point from 2026 and reducing the tax-free wealth threshold to EUR 51,396.   

Employment tax credit
From 2027, the employment tax credit (arbeidskorting) can no longer be applied to social security benefits that are paid through the employer’s payroll, as was already the case with benefits paid by a benefits agency. The proceeds will be used to contribute to funding of the legal aid system.        

Increase in Invalidity Insurance Fund contributions
Contributions to the Invalidity Insurance Fund (Arbeidsongeschiktheidsfonds, Aof) will be structurally increased by EUR 225 million from 2026 onwards. Moreover, to ensure that the difference between the two contribution rates remains at the desired level, in 2026 and 2027 the low Invalidity Insurance Fund contributions for small employers will successively decrease by 0.21 and 0.23 percentage points, respectively, while the high contributions (for medium-sized and large employers) will increase by 0.03% and 0.04%, respectively.        

Bicycle scheme clarified
An addition to income tax currently applies for the provision of regular and electric bicycles that are also available for private use. The Spring Memorandum now clarifies that this addition does not apply to bicycles that are used for commuting to and from work, but are generally not taken home.

Tackling marital property law arrangements                    
Following a Supreme Court ruling, the government proposes a measure to prevent married couples from amending prenuptial agreements to largely avoid inheritance tax at the time of death. In situations involving a community of property, inheritance tax will be levied to the extent that a taxpayer acquires more than 50% upon dissolution of that community or under a matrimonial property setoff clause.

Extension of deadline for filing inheritance tax returns and mitigation of interest on inheritance tax
The 2025 Spring Memorandum releases financial resources for extension of the deadline for filing inheritance tax returns and for a policy-based limitation of interest. The government indicated that the current eight-month period for filing inheritance tax returns is felt to be too tight in practice. However, as yet it is unclear how long an extension is envisaged. The limitation of interest on tax applies for cases where an incorrect inheritance tax return is revised. In that case, interest on tax will only be charged on the difference in tax payable between the final and the incorrect tax return. 

Gift and inheritance tax for biological children
The Supreme Court ruled that no distinction should be made for gift and inheritance tax purposes between children born within or outside marriage, but left removal of the existing inequality to the legislator. The 2025 Spring Memorandum therefore announced a measure to ensure that biological children can now benefit from the same exemptions and rates as legal children.

Energy tax reduction
The energy tax for households will be reduced by EUR 200 million in the years 2026, 2027 and 2028 by increasing the fixed tax credit. This tax credit will amount to EUR 529.10 (excluding VAT) in 2026.  

Consumption tax on non-alcoholic beverages
The government proposes a measure to prevent avoidance of consumption tax on non-alcoholic drinks by adding a small amount of dairy to soft drinks or fruit juices. The exemption for dairy and soya drinks will be reformulated by 2026 and exclusively apply to the purest dairy and soya drinks.  

Remarkable tax arrangements
The 2025 Spring Memorandum features a renewed focus on so-called remarkable tax arrangements. In many cases, concrete measures have already been or are being proposed. Other situations are still under investigation, such as strengthening the approach to dividend stripping. A novelty is the focus on joint ventures between entrepreneurs subject to income tax rules (including sole traders, partners in a partnership, general or otherwise) (IB-ondernemers) and their own private limited companies. The legislator argues that such joint ventures facilitate unintended use of entrepreneurial income tax credits.    

Source:  https://www.rijksoverheid.nl/onderwerpen/overheidsfinancien/documenten/publicaties/2025/04/18/voorjaarsnota-2025