Presented on “Budget Day” (Prinsjesdag), on September 16, 2025, the Dutch Fiscal Plan for 2026 introduces a set of proposals that, although modest due to the interim status of the current government, signal relevant changes to the country’s business environment. The measures, expected to take effect on January 1, 2026, unless otherwise indicated, will still go through debate and voting in Parliament. The proximity of the general elections on October 29, 2025, adds a layer of uncertainty, since the final text will be decided by the new composition of the House.
In the field of corporate taxation, it was confirmed that the Corporate Income Tax (CIT) rates will remain unchanged: 19% for profits up to €200,000 and 25.8% on the exceeding amount. However, one of the most significant changes affects the lucrative interest regime, frequently used in private equity structures and management remuneration plans. The proposal increases the effective tax burden on such income to up to 36%, seeking to align it with the taxation on savings and investments—and importantly, without any transitional rules for existing arrangements. Additionally, in response to a Supreme Court decision from March 2025 regarding the liquidation loss regime, the government intends to eliminate a fiscal asymmetry, making hedging costs for foreign exchange risks non-deductible as of January 1, 2027, in order to compensate for budgetary losses.
In line with international guidelines, Dutch legislation on the global minimum tax will be updated to incorporate the OECD’s administrative guidance, with some changes retroactive to December 31, 2023. The DAC9 directive will also be implemented, simplifying compliance by allowing multinational groups to file a single tax return in one EU Member State, which will then share the information with other relevant jurisdictions. Another measure of great practical importance is the introduction of a transitional regime for Mutual Investment Funds (FGRs), allowing funds that became fiscally opaque under the new 2025 rules to opt to maintain their fiscal transparency status until 2028, thus avoiding multiple status changes in a short period.
Regarding individual taxation and employee benefits, the well-known expatriate regime (“30% ruling”) will face new restrictions. From 2026, the tax-exempt reimbursement for certain extraterritorial expenses, such as additional living costs (including gas, water, and electricity) and communication expenses with the country of origin, will no longer be allowed. This change adds to others already approved, such as the end of the partial non-resident taxpayer status in 2025 and the future reduction of the exemption rate from 30% to 27% in 2027. In addition, from January 1, 2027, a new 12% tax will be introduced on the catalog value of fossil-fuel cars provided by employers for private use, this being a cost to the company, not to the employee.
Finally, in the real estate and consumer sectors, the Real Estate Transfer Tax (RETT) for investors acquiring residential properties will be reduced from 10.4% to 8% as of 2026, a measure aimed at stimulating investment in the housing sector. The 2% rate for owner-occupied housing and the 10.4% rate for non-residential properties will remain unchanged. In the field of VAT, the rate for short-term accommodations, such as hotels and vacation rentals, will increase to the standard rate of 21% from 2026 onwards, with reservations made in 2025 for stays in 2026 already subject to the new rate. Conversely, the government reversed a planned VAT increase for culture, media, and sports, maintaining the reduced rate for these sectors.
It is worth noting that the proposals will still be debated before becoming final, with the final vote in the Senate expected around December 16, 2025.
Published 23 October 2025