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Tax aspects of ‘Energy Shock Resilience Actions’

On 20 April 2026, the government sent a letter to the Senate and the House of Representatives entitled ‘Energy Shock Resilience Actions’ (Acties Weerbaarheid Energieschok), in response to which this letter outlines various scenarios and announces measures. This alert discusses the tax package’s components.

Introduction

The ongoing conflict in the Middle East increasingly leads to disruptions in the supply of oil and oil products. Demand for oil is relatively inelastic, so a decline in supply has a relatively strong impact on the price.

This conflict has resulted in higher prices, increasing uncertainty and heightened volatility in the energy markets across the globe. Its economic consequences are far-reaching and include a decline in global trade and economic growth, rising costs for businesses, higher costs for households and uncertainty in financial markets. What’s more, it directly affects energy-intensive sectors.

Bearing in mind this uncertainty, the government has developed five scenarios for the energy supply, the economic consequences and the impact on households and businesses. The government is preparing for these scenarios and is developing measures to support households and businesses.

Household purchasing power, businesses’ elasticity, and resilience

  • To support citizens’ purchasing power, the maximum tax-free travel allowance will be increased to EUR 0.25 per kilometre, up from EUR 0.23, retroactively to 1 January 2026. This comes down to approximately EUR 0.30 per litre of fuel. The government is calling on employers to use this tax facility, so its benefit actually helps employees.
  • The increase in the deduction rate for the energy investment tax credit (energie-investeringsaftrek, or ‘EIA’) from 40% to 45.5% with effect from 1 January 2027, will make sustainability investments more inviting for businesses. In addition, the SME sector will be supported in implementing energy-saving measures.
  • From 1 July 2026, motor vehicle tax rates for entrepreneurs’ delivery vans will be reduced by 50% for a period of six months, while the rate for goods vehicles will even be temporarily set at zero. And in consultation with the sector, it will be examined whether bespoke measures are possible in respect of the goods vehicle charge.
  • Efforts are underway to accelerate the electrification of the vehicle fleet. The trade-in scheme for fuel-powered cars will be launched as early as the end of 2026. This scheme will allow lower- and middle-income households to have their older fossil-fuel cars (emission classes 1 through 4) scrapped and to subsequently purchase a second-hand electric car, with the help of a subsidy.
  • Access to guarantee schemes will be expanded to enhance businesses’ elasticity. The aim is to provide viable enterprises with better access to finance and liquidity.
  • Another set of government measures is aimed at increasing resilience with respect to the energy demand. The expansion of loans through the Heating Fund, the deployment of energy fixers, and the increase of sustainability grants for owners’ associations, will support households’ energy-saving efforts.
  • An energy emergency fund is being set up, aimed at preventing acute financial difficulties for households if gas prices rise. To this end, EUR 195 million has been set aside.

Budgetary coverage

  • The income tax relief for new businesses will be abolished with effect from 1 January 2027. Evaluations have shown this scheme to have limited effectiveness in promoting entrepreneurship and to involve relatively high implementation costs.
  • The small projects investment credit (kleinschaligheidsinvesteringsaftrek, or ‘KIA’) will be scaled back in 2027, as it is assessed as having limited effectiveness and efficiency. The government is also investigating a possible reform of the scheme, aimed at more effective use of the funds released for stimulating investment and innovation.
  • Effective from 2027, an indexation mechanism will be introduced for excise duty on alcoholic beverages. Unlike other excise duties, this is not currently structurally indexed and so its real value is declining.

Motions and windfall profits in the energy sector

The House of Representatives has adopted motions requesting an investigation into whether companies that may be realising windfall profits due to rising energy prices may contribute to mitigating price rises or supporting vulnerable households. Likewise, it has requested insight into previous measures from 2022 aimed at skimming off windfall profits.

The government currently sees no evidence of windfall profits in the gas market. As for the oil market, although there are indications that revenues from oil extraction and refining have risen, the development of prices and costs remains uncertain. Moreover, with hardly any oil being extracted in the Netherlands, any additional profits are largely realised abroad. Price trends at Dutch refineries are uncertain, too.

The government considers it complex to define ‘windfall’ in unambiguous terms and believes it is undesirable to unilaterally introduce an additional levy on top of corporate income tax. This must be discussed at the European level. The government refers to measures taken in 2022, such as the temporary solidarity contribution and the inframarginal electricity levy, which were also decided upon at EU level. In this respect it is noted that these levies have led to numerous legal proceedings, both in the Netherlands and elsewhere.

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