Tax rate
The corporate income tax rates will remain unchanged, as in previous years. The lower rate of 19% will continue to apply to profits up to €200,000, just as in 2025. For profits exceeding €200,000, the rate remains 25.8%.
The Budget Day documents indicate that no adjustments will be made to the corporate tax rates for now. The development can be summarised schematically as follows:
|
2022 |
2023 |
2024 |
2025 |
2026 |
|
Lower tax rate
|
15%
|
19%
|
19%
|
19%
|
19%
|
|
Profit treshold
|
€395.000
|
€200.000
|
€200.000
|
€200.000
|
€200.000
|
|
Higher tax rate
|
25,8%
|
25,8%
|
25,8%
|
25,8%
|
25,8%
|
During the discussions on the Tax Plan in the coming months, there may still be adjustments made to the rates and brackets.
Minimum tax (Pillar 2)
Introduction of Pillar 2 legislation
With the entry into force of the Dutch Minimum Tax Act on 31 December 2023, the question arose as to how to deal with the administrative guidelines that the OECD regularly publishes as a guiding explanation of the GloBE Model Rules. The previous cabinet recognised this issue in the Dutch Minimum Tax Amendment Act 2024. With Budget Day 2025, another bill was submitted to include parts of the recent administrative guidelines in the Dutch Minimum Tax Act 2024.
The proposed amendment states that the tax treatment of qualifying tradable tax credits will be brought within the scope of the Minimum Tax Act 2024. The Netherlands currently does not yet have any statutory regulations that are considered to qualify as tradable tax credits, but this may change in the future. Other countries do have this type of tax credit, so it is important that the tax treatment is recognised. The effect is that the balances lead to an additional tax to a lesser extent as opposed to a non-qualifying tax credit.
In addition, rules for currency conversion will be introduced, allowing companies that prepare (consolidated) financial statements in a currency other than euros to apply a correct conversion for the purposes of this Act.
Finally, technical adjustments are proposed for further details on the qualifying domestic additional tax and related Safe Harbour rule, adjustments to relevant taxes and net qualifying income, the temporary Country-by-Country reporting Safe Harbour rule and procedural law aspects of the Act.
Implementation of the EU Directive on the exchange of data on minimum taxes (DAC9)
The proposed Implementation of the EU Directive on the exchange of data on minimum taxes regulates an automatic exchange of the annually submitted additional tax information returns with other countries. In principle, group entities that fall under the Minimum Tax Act 2024 must file an additional levy information return annually in all Member States in which they are established. This can cause a considerable administrative burden. Administrative relief is therefore needed to allow multinational groups to submit only one additional tax information declaration when States are covered by a qualifying agreement. The EU Directive 2025/872 is a multilateral qualifying agreement between the Member States, which means that multinational groups only must submit the additional tax information declaration in one Member State. The Member State in which the additional tax information declaration is submitted shall be responsible for the exchange of the relevant distinct parts of the additional tax information declaration with other Member States.
Lucrative interest regime
The lucrative interest regime is intended for persons who perform work for a company and (also) acquire an interest in the form of shares, profit-sharing claims, or other property rights as remuneration for their work. These initially often limited interests can then grow into a significant advantage for the recipient.
The lucrative interest scheme designates benefits from a lucrative interest as the result of other activities and taxes them in Box I. In many cases, this leads to a tax burden of 49.5%. A lucrative interest can also be held 'indirectly' through a holding company. In that case, the person who performs the work can opt for taxation in Box II. This is subject to the condition that at least 95% of the income from the lucrative interest is distributed in the same year.
Tax burden on lucrative interest
The tax burden for both options can be summarised as follows.
| Option Box 1 |
Rate IB |
Corporate income tax rate |
Rate Total |
|
Box 1 < €67,804
|
37,5%
|
|
37,5%
|
|
Box 1 > € 67,804
|
49,5%
|
|
49,5%
|
|
Option Box 2
|
|
|
|
|
Box 2 < € 67,804
|
24,5%
|
19%
|
38,9%
|
|
Box 2 > €67,904 < €200,000
|
31%
|
19%
|
44,1%
|
|
Box 2 > € 200,000
|
31%
|
25,8%
|
48,8%
|
Although both choices currently result in a similar tax burden, there is the opinion in the House of Representatives that the current scheme leads to under taxation in Box II, especially for private equity managers. This has led to the motion by the House Member Idsinga, in which the government is requested, as part of the 2026 Tax Plan, to submit a bill that taxes benefits obtained by private equity managers more heavily in Box II.
The bill included in the Tax Plan introduces an increase in the Box II rate via a base-broadening multiplier. This multiplier multiplies the benefits from an indirectly held lucrative interest by the fraction A/B, where A stands for the rate in Box III and B for the highest rate in Box II. The idea is that this will be in line with the rate of 36% in Box III. This results in the following combined tax burden.
| Option Box 2 Tax Plan 2026 |
|
|
|
|
Box 2 < €67,804
|
28.5%
|
19%
|
42%
|
|
Box 2 > €67,904 < €200,000
|
36%
|
19%
|
48,2%
|
|
Box 2 > €200,000
|
36%
|
25,8%
|
52,5%
|
Countering the undesirable structure of the lucrative interest scheme
According to the legislator, the option discussed above to tax the lucrative interest in Box II can lead to undesirable tax structures. In practice, taxpayers believe this option can be fully exploited as soon as a substantial interest arises. This is when a holding company is established and the lucrative interest is placed in it. At that time, the acquisition price is set at the market value of the shareholding in the company in which the lucrative indirect held interest is held. In the future, liquidation or sale of the shares may result in a loss from a substantial interest, which will then be set off against the realised benefits in Box II. This is considered undesirable by the legislator.
The 2026 Tax Plan, therefore, contains the proposal to add a new sixth paragraph to Section 3.95b of the Income Tax Act 2001. This paragraph stipulates that the benefit arising from the transition from Box III to Box II is taxed in Box I as income from lucrative interest at the time the benefits are realised. Only after this settlement is the lucrative interest taxed in Box II.
Minimum capital rule
The minimum capital scheme is a specific interest deduction limitation in corporate income tax for a limited number of (large) banks and insurers, intended to achieve a more equal tax treatment of equity and loan capital. Because the generic interest deduction limitation does not apply to banks and insurers, this rule has been introduced.
This rule stipulates that interest on loans above a certain threshold is not deductible at banks and insurers. In principle, it does not apply to internal liquidity management, provided that the taxpayer makes it plausible that the group loans are not directly related to loans obtained from non-group entities.
The 2026 Tax Plan proposes that the taxpayer must also demonstrate that the group loans are not directly related to loans from natural persons. The exception for internal liquidity management turned out to be too broadly formulated, as a result of which loans directly related to financing by natural persons also fell under the exception.
Tax transparency: Fund for joint account (FGR)
As of 1 January 2025, the definition of the Fund for joint account (FGR) has been amended. Part of this change is the removal of the consent requirement, as a result of which some investment funds that were fiscally transparent up to and including 2024 will become independently liable for tax from 2025.
The outgoing cabinet is currently conducting research that may lead to a revision of the FGR definition by 2027. The situation may arise that funds that were transparent until 2025 will temporarily be regarded as independent taxpayers in 2025 and 2026. From 2027 onwards, these FGR could be requalified as transparent. This varying qualification leads to practical challenges in the tax treatment of funds.
To prevent short-term tax liability, a transitional arrangement will be introduced for entities that were fiscally transparent up to and including 2024. The transitional law prevents these funds from being independent taxpayers only for a short period of time in 2025 and 2026. The relevant bodies can choose not to be designated as FGR from 1 January 2025 temporarily, provided that all participants agree by 28 February 2026 at the latest. The condition is that the partners are included in the tax at the end of 2024 for the income from the entity.
In practice, the option usually means that the entities remain fiscally transparent and the participants remain directly liable for tax, as was the case up to and including 2024. By leaving the choice to the body, administrative burdens and implementation costs for the Dutch tax authorities are avoided as much as possible. The choice for the transitional law is made by not filing a corporate income tax return for 2025. The proposed transitional law will expire on 1 January 2028.
Energy investment deduction (EIA)
For the application of the EIA (energy investment allowance), a maximum of €151 million (2025: €120 million) in energy investments can be taken into account in 2026. In a Knowledge Group position (KG:212:2024:7, published on 24 December 2024), it was acknowledged that, under the current legislation, the maximum applies separately to:
- On the one hand, a taxpayer's own energy investments, and;
- On the other hand, the part of the energy investments through a partnership is attributed to that taxpayer.
As a result, in practice, a BV could claim the EIA for more than €120 million (2025 ceiling) in energy investments.
The proposed amendment to the 2026 Other Tax Measures Bill introduces an 'aggregation ceiling', which means that the total amount of energy investments taken into account for own investments and investments through partnerships together amounts to a maximum of €151 million per taxpayer per year.
Carbon Border Adjustment Mechanism
The European Carbon Border Adjustment Mechanism (CBAM) will come into full force on 1 January 2026, after which importers of certain goods will have to purchase certificates to compensate for CO₂ emissions (the price of which is linked to the EU ETS). This is a trading system aimed at fair CO₂ pricing and ensures that authorised CBAM declarants are allowed to import CBAM goods and must submit annual declarations. The Dutch bill implements this European regulation by supplementing the Environmental Management Act.
This mechanism requires importers of carbon-intensive products such as steel, cement, and aluminium to purchase CBAM certificates that compensate for the CO₂ emissions of their production outside the EU. This instrument is not a formal tax, but a trading system that creates price equality between EU-produced and imported goods in terms of their carbon footprint.
The designation of the Ministry of Finance as the selling (and buying-back) authority for CBAM certificates also raises possible questions about the capacity to carry out this task within the existing organisational structure.
The prohibitions and enforcement powers for the Dutch Emission Authority (NEa) will also be introduced for further effectiveness of the system. The introduced tiered sanction structure (ranging from €100 per missing certificate to fines of €450,000 or 10% of turnover) deserves further attention in the context of proportionality for smaller companies, as also proposed under the so-called Omnibus proposal. This is a separate process that focuses on simplifying the reporting obligation during the transition period, for example, by easing obligations for small importers and extending the reporting periods.
We would like to mention here that the European Parliament approved the CBAM simplifications by a large majority on 10 September 2025. These changes raise thresholds, extend reporting deadlines, and reduce administrative burdens, while maintaining environmental objectives.
A legal basis for data exchange is also introduced, and for further elaboration by ministerial regulation.
For more information about CBAM, please refer to our most recent article: Carbon Border Adjustment Mechanism (CBAM) Implementation Bill | Grant Thornton.
For businesses that fall within the scope of the 2025 Budget Day tax measures, we highly recommend taking a closer look at how these measures impact your operations. Despite no major reforms, these measures can impact your daily operations.
If you have any questions or need tailored advice, don’t hesitate to reach out to our team.
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