Dutch Budget Day 2025 – key tax measures for international businesses

Below is a selection of key measures. These measures may impact your business or personal situation. We are happy to think along with you and explore what they mean for your specific circumstances. Feel free to reach out to our tax team.

Corporate income tax

Temporary opt-out for partnerships qualifying as FGRs

Due to a revised interpretation of the definition of a fund for mutual account (FGR), certain partnerships may become subject to corporate income tax as of 1 January 2025. A temporary opt-out regime allows entities previously treated as fiscally transparent to elect not to be considered an FGR for 2025 and 2026. The election must be made by 28 February 2026.

Open norm for appropriate equity in flow-through entities

The current safe harbour for equity requirements in flow-through entities will be replaced by an open norm, allowing for a substance-based assessment. This aims to prevent tax avoidance through undercapitalised conduit structures and aligns with OECD principles.

Minimum tax (Pillar Two)

Second amendment of the Minimum Taxation Act 2024

As part of the Tax Plan 2026, the Netherlands has proposed a second set of technical adjustments to the Minimum Taxation Act 2024. These amendments refine the Dutch implementation of the Pillar II rules, which applies to multinational enterprises with annual consolidated revenue of EUR 750 million or more in at least two out of four fiscal years immediately preceding the tested fiscal year.

The proposed amendments are designed to align national legislation with OECD administrative guidance not yet incorporated into Dutch law, while also clarifying the application of existing provisions. Most measures are set to apply retroactively from 31 December 2023, with remaining provisions entering into force on 31 December 2025.

Implementation of EU Directive DAC9

The Netherlands will implement DAC9 legislation, facilitating automatic exchange of Pillar Two-related information across EU tax authorities. A centralised Top-up Tax Information Return (TTIR) can be filed at group level using a standard EU template, reducing administrative burden. This means that multinationals within affected by Pillar II can opt for one TTIR that covers all EU Member States.

In August 2025, the Netherlands joined the OECD’s Multilateral Competent Authority Agreement (MCAA) on the exchange of GloBE Information Return (GIR) which sets the terms for automatic GIR data exchange. The agreement currently covers 16 jurisdictions, including some non-EU states, with which the Netherlands will exchange GIR information. The list of jurisdictions is expected to grow in the coming months.

Income tax

Increased tax burden on lucrative interests

From 2026, a multiplier will apply to income from lucrative interests structured in Box 2, increasing the effective tax rate in Box 2 to 28.45% (first bracket) and 36% (second bracket). No transitional rules apply.

Anti-abuse rule for lucrative interests

To prevent artificial loss recognition, a new rule will disallow Box 2 losses where a substantial interest is acquired after holding a lucrative interest in the same entity.

Startup stock option regime

A new regime defers taxation on employee stock options until sale and limits the taxable base to 65%, reducing the effective rate to 32.17%. The measure is expected to take effect on 1 January 2027, pending further legislative development.

Wage tax

Final year for partial non-resident status under 30%-ruling

The partial non-resident tax status has been abolished as of 2025. Expats who qualified in 2023 may continue to opt for it until end of 2026.

Employment classification reform

The Clarification of Employment Relationships Act (Wet VBAR) codifies recent case law and introduces a legal presumption of employment for self-employed individuals earning less than €36/hour. A draft decree was published on 12 September 2025 for consultation.

Tightening of ETK Scheme

From 2026, only employment-related extraterritorial costs may be reimbursed tax-free. Living expenses such as utilities and private communication are excluded.

Pseudo-final levy on fossil-fuel company cars

From 2027, employers must pay a 12% levy on the list price of fossil-fuel company cars used privately. A transitional period applies until 17 September 2030 for cars provided before 2027.

VAT

Reduced VAT rate for certain sectors

The planned increase to 21% has been cancelled for Culture, Sports and Media. The 9% reduced VAT rate remains in place for these sectors. Radiopharmaceuticals will also benefit from the reduced rate.

Real Estate

VAT adjustment for real estate services over €30,000

From 2026, VAT adjustments will apply to real estate services (e.g. renovation) exceeding €30,000 per building, requiring tracking of property use during the adjustment period.

Transfer tax on second Homes Lowered to 8%

As of 2026, the transfer tax rate for non-primary residences will be reduced from 10.4% to 8%. A proposal to further reduce the rate to 6% is pending parliamentary approval.

Energy

Reduction CO₂ levy for industry

The Dutch government has announced a revised carbon pricing approach for the period 2026–2030, affecting certain industrial installations covered by the EU Emissions Trading System (ETS). The national carbon levy rate will be set at €78.67 per tonne of CO₂, alongside an updated dispensation factor of 1.023.
Given current projections for the EU ETS price, which is expected to exceed the national levy from 2027 onward, the national carbon charge may no longer be payable from that point. In addition, installations that align with EU decarbonisation targets are expected to be effectively exempt from the national levy starting in 2026

Energy tax

The Dutch Government has introduced several changes to the energy tax framework, aimed at supporting the energy transition and improving clarity for taxpayers.

• Energy tax: A revised price path for the general energy tax reduction will result in a modest decrease in household energy bills over the coming years.
• Reduction energy tax rate for hydrogen: From 1 January 2026, a specific energy tax rate will apply to the energetic use of pure hydrogen. This rate will be aligned with the electricity rate in the fifth bracket and will apply uniformly to grey, blue, and green hydrogen.
• Broader tax relief for electrolytic processes: The exemption for electricity used in electrolytic processes will also be expanded. It will now cover electricity directly used in the demineralisation or electrolysis of water, as well as in the purification and compression of the resulting hydrogen.