Key features of the proposed regime

• Only available for start- en scale ups qualified as such by the governmental body “Rijksdienst voor Ondernemend Nederland” (RVO)
• Share options remain taxable as employment income, but the tax base is reduced to 65% of the economic benefit.
• This results in an effective tax burden that broadly alligns with Box 2 taxation (substantial interest).
• Taxation is deferred until the actual disposal/sale of the shares.
• No taxation upon termination of employment; tax is triggered solely upon disposal of the shares.
• Transitional law for the situation where the qualification ast start-up / scale-up has lapsed.

If you would like to discuss how this regime fits within your existing incentive plans, the Borgen Tax team will be happy to assist.