Tax

Pillar 2 and Dutch Tax Regimes

By:
Tim van Brederode,
Wouter Kreukniet
21 Jan 20262 min read
Pillar 2 and Dutch tax regimes
Dutch tax incentives such as the innovation box and participation exemption have long been tools for tax efficiency. Under Pillar 2, however, these incentives can create permanent differences that trigger additional tax liabilities. For multinational groups operating in the Netherlands, understanding this interaction is critical.
Contents

Why It Matters

The GloBE rules impose a minimum effective tax rate of 15% in each jurisdiction. Incentives that reduce taxable income may lower the effective tax rate below this threshold, resulting in a top-up tax. This means strategies that once delivered savings could now increase exposure.

Balancing Compliance and Efficiency

Our experts unpack these complexities and explain how to assess your group’s position. The goal is not to abandon incentives but to integrate them into a broader compliance strategy. By modelling the impact of Pillar 2 on Dutch regimes, you can:

  • Identify potential risks early.
  • Adjust structures to maintain efficiency.
  • Avoid unwelcome surprises during reporting.

Your Next Step

Watch Episode 3 of our video series for practical insights on managing Dutch tax incentives under Pillar 2. For tailored advice, contact our team. We are here to help.

The video is playing. This video is playing in mini-player mode.
TAGS  
Authors
  • Tim van Brederode
    Tim van Brederode Tim has been with Grant Thornton since 1 October 2024 as Senior Manager Tax Knowledge Centre. View Profile
  • Wouter Kreukniet
    Wouter Kreukniet Wouter Kreukniet is a tax advisor at Grant Thornton and is specialized in (international) tax advisory with a special focus on European tax legislation, withholding taxes and permanent establishment questions. View Profile

Related articles

View more

Dutch Dividend Withholding Tax Exemption

International Tax advice

When a Dutch company distributes dividends, it is in principle required to withhold 15 % dividend withholding tax on the gross dividend. However, under certain conditions the Dutch law provides for a withholding tax exemption on dividends to non resident shareholders. In this article we will explain more about how this works.

Faisal Janjua
| 3 min read | 13 Apr 2026

EU Tax Omnibus Directive: what’s changing

tax

The European Commission is preparing an “omnibus directive” on direct taxation, expected in June 2026. This is not a new tax initiative, but an effort to review and streamline how existing EU direct tax rules operate together in practice.

Monique Pisters
Sasha Kerins
| 2 min read | 31 Mar 2026

Does the Energy Investment Allowance also apply to your investment?

Sustainable tax

Is your organisation investing in CO₂ reduction, energy-efficient technologies and renewable energy? If so, you may qualify for the Energy Investment Allowance (EIA): an attractive tax scheme that encourages entrepreneurs to invest in energy-saving or sustainable business assets. With the EIA you do not only benefit from lower energy consumption and emissions, but also from tax relief. In addition, the EIA budget increases each year; in 2026, it amounts to no less than €460 million. Which business assets fall under the EIA, and what conditions must your investment meet?

Pierre Docx
Danny Niesing
| 4 min read | 25 Feb 2026
    View more