Pillar 2 and Dutch Tax Regimes

Tax

By: Tim van Brederode, Wouter Kreukniet

21 Jan 2026 2 min read

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.

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Authors

  • 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 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

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