By: Pierre Docx, Michiel Maas, Kimiya Khiabani, Miranda Balk Reyes
05 Nov 2026 8 min read
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For the WBSO, what matters most is whether your business itself pushes technical boundaries. Even an existing product, process or software system can therefore form the basis for a promising WBSO project, as long as the development goes beyond routine work and involves concrete technical bottlenecks and uncertainties. Whether a technically promising project ultimately qualifies often depends on clearly identifying and substantiating the genuine technical bottlenecks, development activities and uncertainties.
We are happy to identify where the technical innovation lies and translate this into a sharp, realistic and verifiable application to the Netherlands Enterprise Agency (RVO).
The WBSO reduces the costs of research and development work. Companies with employees deduct the benefit via payroll tax; self‑employed entrepreneurs receive, under certain conditions, a deduction in income tax. RVO assesses the applications and, upon a positive evaluation, issues the R&D declaration. The scheme is available to companies with employees who perform R&D activities, to self‑employed persons who carry out these activities themselves, and to start‑ups that meet the additional conditions.
Companies may be leaving WBSO value on the table in two ways. First, qualifying technical development may be taking place without being recognised as a potential WBSO project. Second, a company may already use the WBSO but lack an audit-proof time and project administration. The latter can lead to financial risks during an RVO audit. A periodic review of the WBSO administration may help prevent corrections and discussions afterwards.
A project can qualify for the WBSO when the following elements are jointly present:
The assessment is made from the perspective of the company submitting the application. The fact that a similar product, process or software system already exists in the market does not exclude the application of the WBSO. However, the company must develop its own technical knowledge to solve its own bottlenecks.
Software: development of technically new software for scalability, security or data processing, where existing architectures are insufficient.
Energy and storage: development of a battery or energy management system with technical uncertainties regarding efficiency, heat management, lifespan or control.
Many software companies wrongly assume that improving existing software does not qualify. Yet technical issues surrounding scalability, performance, cybersecurity, AI integration and complex data architectures may fall under the WBSO when they require the company to resolve genuine technical bottlenecks through its own development work.
The amount of the WBSO benefit depends on the business structure. For companies subject to payroll tax, the following proposed rate reductions apply in 2027:
| Innovative start-ups | First bracket | 50% |
|---|---|---|
|
Bracket
|
R&D base
|
Reduction
|
|
First bracket
|
Up to and including €391,020
|
36%
|
|
Second bracket
|
Above €391,020
|
16%
|
The percentages are calculated over the R&D base, consisting of the R&D wage increased by a fixed amount or by approved actual costs and expenses. The fixed R&D hourly wage for companies without historical R&D hourly wage is proposed to be €33 in 2027, instead of €29 in 2026. These parameters remain subject to the completion of the parliamentary process and should therefore not yet be treated as final.
Many companies still treat the WBSO as if it were merely a subsidy. From 2027, that could be a costly misconception. Depending on the company’s profitability, the WBSO declaration can also be an important building block for obtaining an additional benefit within the innovation box, provided all applicable innovation box conditions are met.
Take an innovative business with €900,000 profit and several thousand development hours per year. In addition to a direct WBSO benefit of, for example, €30,000, the WBSO declaration may provide significant access to the innovation box. Under the lump sum regime, up to €100,000 of profit can be taxed at the effective innovation box rate of 9%, instead of the standard corporate income tax rate of 25.8%. This results in an additional benefit of €16,800, bringing the total tax advantage in this example to €46,800 per year. If the regular innovation box can be applied to a larger portion of the qualifying innovation profit, the benefit may increase considerably further.
This example is illustrative. The actual benefit depends on the company’s R&D activities, wage costs, qualifying innovation profits and overall tax position. A WBSO declaration does not automatically result in access to the innovation box.
The most striking development? For application of the lump‑sum innovation box regime, it no longer needs to be determined separately which part of the profit results from innovation. More and more often, the WBSO declaration acts not only as a subsidy instrument but as a gateway to a broader innovation strategy. From 2027, this additional benefit can increase further if the proposed expansion of the lump‑sum innovation box scheme is definitively adopted.
The question, therefore, is no longer whether the WBSO alone is attractive enough, but how much benefit you leave on the table when you don’t apply for WBSO.
Self‑employed individuals must spend at least 500 hours per calendar year on R&D. To apply the R&D deduction, they must also meet the hours criterion of at least 1,225 hours for their business. For legal entities such as a BV, the 1,225‑hour requirement does not apply; this condition only applies to self‑employed persons using the self‑employment deduction.
The applicant must be an entrepreneur for Dutch income or corporate tax purposes. A company with staff must also pay Dutch payroll tax for employees performing R&D work. The company itself carries out the requested R&D activities and bears substantive responsibility for them.
A successful WBSO process does not end when the application is approved. The application, execution of the project and supporting administration must remain aligned throughout the year
Define the development project precisely. Describe the technical end goal, the bottleneck and the uncertainties that cannot be solved with existing knowledge or standard techniques. Develop potential solution approaches and make a substantiated estimate of expected R&D hours and, where applicable, costs and expenses.
Translate the development project into a clear and verifiable application. Clarify what the company itself develops, why the solution is not known in advance, and which technical activities are carried out. Submit the application on time and ensure that additional questions from RVO are answered consistently.
Execute the project in line with the application and record the hours, technical progress, tests, choices and results during the process. Use, for example, the official RVO model time sheet. After completion, report the actual R&D hours and, where applicable, the actual costs and expenses.
Good R&D administration aligns with the application and provides insight into which activities have actually been carried out. From the start of the project, record the realised R&D hours per employee, per project and per day. Also record the nature, content and progress of the work and keep relevant documentation such as designs, calculations, test results, analyses and technical reports. When opting for actual costs and expenses, these amounts must also be recorded per project in a verifiable way. Ensure that time registration, project administration and cost administration are consistent with each other and remain up to date during the project.
Risks in the file often arise from reconstructing hours afterwards, insufficient alignment between time and project administration, inclusion of regular implementation work, failure to record technical decisions, or missing documentation of failed tests. It is precisely those failed tests that demonstrate that the outcome was technically uncertain in advance. A current and coherent administration reduces the risk of questions and corrections during an RVO audit.
Grant Thornton supports throughout the entire WBSO process: from quick scan and opportunity assessment to preparing the application, liaising with RVO, and setting up time and project administration. We also support the realisation report and assess alignment with the innovation box and broader innovation and sustainability objectives. In this way, you make optimal use of the fiscal advantage and build a technically substantiated dossier that matches your application.
Would you like to know whether a development within your company is technically new enough for the WBSO? We are happy to assess a proposed project, existing application or R&D administration and identify concrete opportunities, points of attention and possible file risks.
Would you like to discuss these insights further? Get in touch with us.
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