Rate structure

The general corporate income tax rate is 25.8% in 2025. A reduced rate of 19% applies to taxable amounts of up to EUR 200,000. Although the evaluation of this rate step-up was negative, the current caretaker government seems unwilling to change it.

Minimum taxation

In line with recent OECD administrative guidance, on Budget Day amendments will once again be proposed to the Minimum Taxation Act 2024. Another bill is expected to be introduced for the implementation of DAC9. This Directive provides for a centralised top-up tax information return in a single Member State, for all jurisdictions. This will reduce the regulatory burden on multinationals.

Remedy of liquidation loss scheme

On 21 March 2025, the Supreme Court gave judgment on the liquidation loss scheme, which, as the government argues, will result in a significant budgetary loss. The State Secretary is now examining the possibility of financial coverage within or outside the liquidation loss scheme and expects to be able to inform the House of Representatives about this on Budget Day.

Rate structure

In 2025, a three-bracket rate will apply in Box 1 (income from work and home) for wage and personal income tax purposes. Up to an income of EUR 38,441, a rate of 35.82% applies. Next, a rate of 37.48% will apply up to an income of EUR 76,817, while the excess is subject to the top rate of 49.50%. The rate in Box 2 (income from substantial interest) will be 24.5% in 2025 up to a Box 2 income of EUR 67,804 and 31% on the excess. Box 3 (income from savings and investments) has a flat rate of 36%. It is unclear whether these rates will change. The 2025 Spring Memorandum does show that the inflation in 2026 will only be partially offset (46.2%) by an increase of the bracket limits and tax credits.

SME profit exemption and self-employed deduction

The SME profit exemption is likely to be upheld at 12.7% in 2026. On the other hand, the self employed deduction will be further reduced, to EUR 1,200 in 2026 and EUR 900 in 2027. In 2025, this deductible item is still EUR 2,470.

Abolition of business discontinuation relief and co-working partner’s relief

Effective from 2027, the business discontinuation relief for personal income tax purposes will be reduced by 75%, to EUR 908 (2025: EUR 3,630) and abolished entirely in 2030. The legislator’s argument for doing this is an evaluation that has shown the scheme to no longer serve a legitimate purpose. The same argument is used for the phasing out of the co-working partner’s relief for personal income tax purposes. First, the deduction percentages will be significantly reduced in 2027, after which the scheme will be abolished completely in 2030. The proceeds will be used to finance the new tax scheme for start-ups and scale-ups.

Increase of fixed sum for other assets in Box 3

The introduction of the new Box 3 system, with tax being levied based on the actual return realised, has been postponed until 2028. In addition, the Box 3 Rebuttal Scheme Act will only allow personal use of immovable property to be taken into account effective from 1 January 2026. The budgetary loss will be offset by increasing the fixed sum for other assets in Box 3 by 1.78 percentage points as of 2026 and by reducing the debts threshold to EUR 51,396.

Box 3 remedy legislation

The Box 3 Rebuttal Scheme Act retroactively remedies a tax leak relating to the purchase of bonds with accumulated interest, with effect from 4 p.m. on 25 August 2025. This is done by abolishing the exemption for short-term instalments, as a result of which the accumulated interest is no longer exempt. The rule in the rebuttal scheme under which bonds and other securities with current (interest) instalments must be valued at the closing price on the final trading day of the relevant year is also abolished. The reason is that this price is exclusive of accumulated interest. Instead, the market value applies.

Another measure provides for the exclusion of the application of the value with vacant possession ratio for rented homes in Box 3 in the event that related parties engage in non-arm’s length transactions.  

Pseudo-final levy on non-zero emission lease cars

The government is expected to propose the introduction of a pseudo-final levy of 52% effective from 2027, for employers who do not provide their employees with fully emission-free cars. The tax base consists of the additional tax liability for the private use of these cars.

Start-ups and scale-ups

A tax scheme for wage tax purposes will be introduced that provides for narrowing the tax base to 65% of the income from share options for employees of start-ups and scale-ups, which will have an impact on the Box 1 levy for personal income tax purposes. As a result, the effective tax will be comparable to the situation in which the share options would be taxed in Box 2.

Increase in contribution for the Invalidity Insurance Fund (‘Aof contribution’)

The contribution for the Invalidity Insurance Fund (Arbeidsongeschiktheidsfonds, or ‘Aof’) will be increased by EUR 225 million on a structural basis from 2026 onwards and there will be a shift in 2026 and 2027, with the low Aof contribution for small employers being reduced by 0.21 percentage points (2026) and 0.23 percentage points (2027), respectively. On the other hand, the high Aof contribution (medium-sized and large employers) will increase by 0.03% (2026) and 0.04% (2027), respectively. This is to ensure that the difference between the two contribution rates remains at the desired level.

Clarification of bicycle scheme

The provision of electric and regular bicycles that are also available for private use is subject to an additional tax liability for wage tax purposes. It is clarified that this additional tax liability does not apply to bicycles that are used for commuting but are generally not taken home.

Making the threshold exemption for the early retirement scheme permanent

The threshold exemption for the pseudo-final levy in early retirement schemes (regeling vervroegde uittreding, or ‘RVU’) will be made permanent with benchmark dates. Both the amount of the threshold exemption for the early retirement scheme and the rate for the portion in excess of the threshold exemption for the early retirement scheme will be increased.

Business succession scheme

In its April 2022 report, the Netherlands Bureau for Economic Policy Analysis (CPB) concluded that although the business succession scheme (BOR) and the transfer facility (DSR ab) are effective, certain components are inefficient, while a number of bottlenecks were identified as well. Under the 2025 Tax Plan, access to the BOR and the DSR ab will be limited to ordinary shares representing at least 5% of the subscribed capital as of 1 January 2026. A number of anti-abuse provisions will also come into force at that time, to combat the so-called ‘rollator investments’ (situations where an elderly and wealthy relative acquires an interest in an heir’s company) and ‘double BOR’ structures.

Longer inheritance tax return period and moderation of interest on tax

The 2025 Spring Memorandum states that the current period of eight months for filing inheritance tax returns is considered too short in practice. This period is expected to be extended to twenty months. The calculation of interest on tax for inheritance tax purposes will be aligned with this.

Addressing matrimonial property law arrangements

On the back of a judgment by the Supreme Court, a measure is proposed to prevent married couples from amending their marriage contracts in anticipation of death in order to largely avoid inheritance tax. If it concerns community of property with unequal fractions, inheritance tax will henceforth be levied to the extent that a taxpayer receives more than 50% upon dissolution of that community. The same applies to a (final) setoff clause subject to which the assets are divided other than equally.

Gift and inheritance tax relating to biological children

The Supreme Court has ruled that for gift and inheritance tax purposes it is not permitted to distinguish between children born within or outside of marriage, but left it to the legislator to eliminate the existing inequality. The 2025 Spring Memorandum therefore announces a measure that will ensure that biological children will henceforth be able to benefit from the same exemptions and rates as legal children.  

Rate for residential properties

The transfer tax rate for the acquisition of residential property will be reduced from 10.4% to 8% as of 1 January 2026. Other immovable property will continue to be subject to the general rate of 10.4%. The government wants this measure to stimulate investment in rental properties. The reduced rate of 2% will continue to apply to the acquisition of homes intended for long-term self occupation. The so-called first-time buyer exemption will remain in place, too.  

Reversal of VAT rate increase for culture, media and sports

The increase in the VAT rate for culture, media and sports from 9% to 21% included in the 2025 Tax Plan will be reversed, on the back of which the promised compensation for schools for VAT on teaching materials will also be cancelled. The VAT increase on accommodation (short stays as part of the hotel, boarding house and holiday let business) has been greenlighted, unless a motion of 2 September 2025 to also withdraw this amendment is adopted. A transitional arrangement has been implemented that aims to subject overnight stays in 2026 to the increased rate, even if the reservation and payment were already made in 2025.

VAT adjustment in respect of property investment services

Effective from 2026, the adjustment scheme for VAT purposes will be extended to property investment services. Each service will be subject to a threshold amount of EUR 30,000 in order to strike a balance between the intended effect of the measure and the implementation costs. A five year adjustment period has been chosen. With this measure, the legislator wants to combat tax-saving structures involving short-term rents subject to VAT.

Corrective measure in respect of VAT exemption for social or cultural services

As a rule, supplies and services of a social or cultural nature are exempt from VAT, provided there is no profit motive. However, a legislative amendment effective from 1 January 2026 (replacing facilitation policy) extends this exemption such that institutions with a profit motive may benefit as well. This reverses an undesirable consequence of a 2023 Supreme Court judgment that excluded institutions with a profit motive from the exemption.

Objection and appeal against nil return

Previously, there was uncertainty as to whether an objection or appeal could be file or lodged, respectively, against a nil return for VAT purposes. A legislative amendment will now explicitly allow both objections and appeals in such cases as of 1 January 2026. Under the State Taxes Act, ‘payment’ is also understood to mean a payment of nil.

Copies of invoices and import documents for refund requests through foreign portal sites

Effective from 1 January 2026, entrepreneurs not established in the Netherlands who request a refund of Dutch VAT through a foreign portal site will be obliged to include the relevant invoices and import documents directly in the request, insofar as their value (excluding VAT) exceeds EUR 1,000 (EUR 250 for fuel invoices).

Adjustment of zero rate for ships

By listing warships separately in Table II, it is clarified that the zero rate applies to the delivery, conversion, repair, maintenance, chartering and rental of warships, without this being subject to additional conditions. This amendment is expected to come into force on 1 January 2027.

Differentiation of air passenger tax

In 2025, the air passenger tax will be EUR 29.40 per departing passenger, regardless of their destination. However, the government is expected to propose that this tax be made dependent on the distance flown from 2027 onwards. This will have a budgetary impact of approximately EUR 250 million.

Rate discount for electric cars

The rate discount for electric cars in motor vehicle tax will be increased from 25% to 30% in the period from 2026 to 2028. The government wants to achieve a tax rate that is more equal to that of petrol cars, as electric cars are considerably heavier.

Suspension of CO2 tax on industry

On 25 June 2025, the House of Representatives passed a motion calling on the government to abolish the CO2 tax on industry in view of the competitive position of Dutch heavy industry. In response, the government has indicated that it wishes to suspend the CO2 tax until 2030 by applying a zero rate. However, this requires a change in the law. It is unclear whether this will be part of the 2026 Tax Plan package.

Reduction of energy tax

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

Abolition of the tax cap on tap water

The tax cap on tap water will be increased from 300m3 to 50,000m3in 2026 and will be abolished altogether in 2027. However, the tax base will be narrowed to water of drinking water quality in 2027.

Consumption tax on non-alcoholic beverages

A measure is proposed to prevent the consumption tax on non-alcoholic beverages from being evaded any longer by adding a small amount of dairy to soft drinks or fruit juices. The exemption for dairy and soy beverages will be reformulated as of 2026, so that it will only apply to the purest dairy and soy beverages.

Amendment to right of access

An amendment was adopted in the 2024 Tax Plan that provides for citizens’ legal right of access to their own tax files. However, the current design poses implementation problems. It is expected that on Budget Day, a proposal will be made to amend the right of access such that the Tax Administration will be able to implement it (in the long term).