Netherlands – Budget Day 2026 – tax plans for the coming years

On 15 September 2026, the Dutch government proposed several tax bills as part of the 2026 Budget Day. Most of these bills are planned to come into force as per 1 January 2027. However, the Dutch government currently does not have a majority in parliament, so the coming months will show for what measures sufficient support can be obtained. Below are some of the highlights relevant for foreign businesses and investors:

Real estate transfer tax (RETT)

1. The general RETT rate for residential properties is lowered to 7% from 8% per 1 January 2027. The RETT rate for other properties remains at 10.4%.
2. An exemption from RETT was introduced for the transfer or social housing by public housing corporations to other public housing corporations.
3. The acquisition of shares in a company owning Dutch real estate for lease may be subject to Dutch RETT. The acquirer is obliged to file a return and pay the tax due. The company itself is obliged to request the tax authorities for an invitation to file the return. Currently, there is no formal obligation for the seller. An obligation for the seller to notify the Dutch tax authorities is proposed to be implemented per 1 January 2028. Noncompliance may result in a penalty. Although considered, the proposal does not entail liability for the seller for the RETT payable.

Corporate income tax (CIT)

1. Public housing corporations are proposed to be exempt from the EU ATAD 1 interest deduction limitation as per 1 January 2028. No specific legislative proposal has (yet) been proposed for this change, but it has been included in the budgetary calculations.
2. The participation exemption is no longer fully applicable to foreign exchange results on currency hedging instruments entered into in relation to participations as per 1 January 2027. Currently, an arbitration possibility exists whereby certain costs of these instruments can be deducted whereas gains can be exempt. Based on the amendments, losses or gains such as the expected appreciation or depreciation of a currency vis-à-vis the euro, which are priced in in the price of the instrument are no longer exempt. Only the results from the actual, unexpected changes in the value of the instrument may be exempt under the participation exemption. Transitional rules are proposed for instruments entered into before 15 September 2026.
3. An additional deduction besides regular depreciation is available for certain energy saving assets (Energie investeringsaftrek), which currently amounts to 40% of the investment amount. This percentage will be increased to 45.5% as per 1 January 2027.
4. Rollover relief is available for mergers and demergers subject to certain conditions. These rules contain the presumption that the merger or demerger was entered into the with the purpose of avoiding Dutch CIT if the involved companies are disposed of to a third party within 3 years of the (de)merger. In early 2026, the Dutch Supreme Court held that this presumption is contrary to the EU merger directive which requires that tax authorities provide proof and establish whether certain transactions were entered into with the (principal) purpose to avoid tax. The CIT is now proposed to be amended to be in line with this requirement. Note that the general anti abuse clause based on the ATAD 1 directive and the EU law obligation to combat the abuse of EU law still applies and must be taken into account.

Global minimum tax (Pillar 2)

The Netherlands applies the global minimum tax (Pillar 2) and aims to implement all the OECD and EU rules in this respect. On 5 January 2026 the OECD issued the Side-by-Side package providing for simplifications and requirements for national tax systems to qualify as equivalent tax systems to pillar 2. The Netherlands will fully implement the Side-by-Side package meaning that the following is implemented in Dutch law:

1. The Simplified ETR Safe Harbour for financial years starting on or after 31 December 2026 (The Netherlands also implements the option to allow application for financial years on or after 31 December 2025);
2. The extension of the Transitional CbCR Safe Harbour to financial years starting on or after 31 December 2027 and ending before 1 July 2029;
3. The Side-by-Side system: the Qualified SbS Regime and the UPE Safe Harbour. As per 1 January 2026 the United States was included in the OECD’s central record; and
4. The substance based tax incentives allowing certain qualified tax incentives to be considered an addition to the covered taxes.

Personal income tax / wage tax

1. A wage tax / personal income tax benefit is introduced per 1 January 2027 for share option incentives provided to employees of start-ups or scale-ups. Taxation is deferred to the actual sale of the options or shares (as opposed to the moment exercise of the options) and the taxable basis is only 65% of the value of the shares. A decision from the Netherlands Enterprise Agency is required for an employer to qualify as a start-up or scale-up, which is defined as a company carrying on a business that is aimed at rapid growth by way of a scalable and repeatable business model that finds its origins in innovation. Furthermore, the shares of the start-up or scale-up may not be listed on a stock exchange or owned for 25% or more by a company that is listed on a stock exchange.
2. Foreign individuals owning a substantial interest in a company that relocates to the Netherlands become subject to foreign substantial interest taxation. This means that they are subject to Dutch personal income tax at a marginal rate of 31% over the profits realized from these shares such as dividends received or capital gains upon disposal. Capital gains are calculated based on the consideration for the sale less the acquisition price. A tax treaty may limit this taxation.
   In case a company is relocated to the Netherlands, the above means that unrealized gains or losses from a period prior the Dutch tax claim may also become part of the taxable basis. Therefore, the taxable basis upon relocation of the company to the Netherlands is set at the fair market value as per 1 January 2027. Exceptions apply if the company was at some point in time a Dutch tax resident company.
3. Earlier this month, it already became apparent that the major issue hanging over the Dutch national market, the savings and investment taxation for individuals (moving from a system whereby a deemed return with an annually set percentage is the taxable basis to a realization or accrual basis system), would again not be further addressed in this tax budget, but at the earliest in the spring of 2027. With this delay, the planned date of 1 January 2028 becomes more and more uncertain.