Other measures

The self-employed deduction is being scaled down. For 2026, the self-employed deduction amounts to € 1,200 (2025: € 2,470). 

Codification of payment deferral upon conversion 

The deferral of payment when an enterprise, converted into a private limited company (BV) or a public limited company (NV) by a foreign taxpayer, is legally established. For example, even in the case of applying the treaty, the amount retained can be transferred to Box 2, subject to conditions, without direct taxation. No interest on overdue tax shall apply during the deferral. 

Clarification of wage definition for the restriction on deductibility for mixed expenses 

The concurrency scheme between the work-related expenses scheme and the restriction on deductibility for mixed expenses in corporate tax, will be clarified technically. 

Possibility of appeal against certain rulings limited  

Under corporation tax, objections to loss setoff and revaluation rulings will henceforth be limited to the amount not yet established. 

Temporary transitional law for mutual funds 

To avoid short-term tax liability, a transitional measure is proposed for mutual funds (fondsenvoorgemenerekening, fgr) which were transparent for tax purposes until 2024. These mutual funds may opt not to be deemed as taxable on a temporary basis, under the current transitional law, with effect from 1 January 2025. A condition is that all participants agree by 28 February 2026. The transitional law applies until 1 January 2028 at the latest and will prevent the funds involved from independently being subject to tax for only a short while in 2025 and 2026. 

Amendment to the minimum capital rule in corporation tax 

The minimum capital rule limits the tax relief of interest for banks and insurers. As of 2024, the minimum capital rule has been eased by excluding, subject to conditions, interest from other group bodies in the limit calculation. It was found that this easing also applies to money loans to natural persons (where banks often collect funds). This amendment partially reverses the previous easing and renders these money loans relevant again for the minimum capital rule. This is in line with the minimum capital rule’s aim to confine the tax incentive of debt financing. 

Take note!  

Check that loans to natural persons are included again in the minimum capital rule calculation. 

Amendment to Minimum Taxation Act 2024 

The Minimum Taxation Act 2024 (Wet minimumbelasting 2024) ensures that multinational companies with a turnover of at least €750 million, effectively pay at least 15% tax on their profits. This Act is an implementation of a European directive based on the OECD’s model rules. This legislative proposal codifies several non-binding OECD administrative guidelines into Dutch legislation. In addition, several technical amendments have been proposed. This amendment has some retroactive effect to financial years beginning on or after 31 December 2023. 

Take note!  

Check whether the retroactive codification of OECD guidelines and technical amendments have an impact on taxpayers for the Minimum Taxation Act 2024. 

DAC8 

Crypto-asset service providers will be subject to a reporting obligation as from 1 January 2026. They must report client and transaction data to the Tax Administration (Directive on Administrative Cooperation, ‘DAC8’). 

Implementation under DAC9 

This bill implements the 8th amendment to the Information Exchange Directive (DAC9) under the International Assistance (Levying of Taxes) Act (Wet op de internationalebijstandsverleningbijheffing van belastingen, WIBB). DAC9 provides for information exchange for implementation of the Minimum Taxation Act 2024 on the basis of which multinational companies with a turnover of at least €750 million, always effectively pay at least an 15% tax on their profits. This amendment to the WIBB allows the Netherlands to share the Minimum Taxation Act return internationally with other Member States. This means that companies are required to submit returns in only one country.  

Take note!  

The Minimum Taxation Act 2024 includes a reporting obligation for the entity filing the returns. 

CBAM introduction in the Netherlands 

This legislative proposal further elaborates the provisions of the CBAM Regulation, establishing a Carbon Border Adjustment (levy) Mechanism. The EU regulation itself also has direct effect. The Minister of Finance is designated for the sale and repurchase of CBAM certificates. The Dutch Emissions Authority (NederlandseEmissieautoriteit, NEa) will be empowered to impose penalties for infringements, such as failure to surrender or insufficient surrender of certificates. There will also be a legal basis for the sharing of data by the Dutch Emissions Authority with third parties.  

Take note!  

Entrepreneurs importing goods with embedded greenhouse gas emissions must be authorised CBAM declarants by no later than 2026. 

Exemption of Online Administrative Business Act (Wmebv) for the Tax Administration and Customs Service 

In order to prevent the Tax Administration and Customs Service from (temporarily) acting in violation of the modernised Section 2.3 of the General Administrative Law Act (Algemene wet bestuursrecht, Awb), they are excluded from application of the Online Administrative Business Act (Wet moderniseringelektronischbestuurlijkverkeer, Wmebv). The Online Administrative Business Act provides that citizens and businesses are given the right to send messages electronically to public bodies and that the paper path continues to exist alongside the digital one. As the Tax Administration and Customs Service cannot yet fully implement this, a temporary exception applies until 1 January 2030. For the Customs Service, a permanent exception partially applies due to contradiction with EU law. 

Tip!  

For objection and return procedures, keep account of deviating rules for electronic messaging to the Tax Administration and Customs Service. 

Right of access to tax files 

Taxpayers and withholding agents will now be granted an active right of access to their tax files. At the latest, on notification of a tax assessment or a decision subject to appeal, all documents relating to the case shall be made available digitally via a portal. The right of access will be introduced step by step for each tax. A temporary arrangement allows the tax inspector to make documents available before a right of access for a tax applies. For decentralised e.g. municipal rates and taxes, the right of access does not apply. 

Tip!  

Use the right of access option, this could also help with objection procedures.