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International Corporate Tax

For internationally operating groups, Prinsjesdag is not expected to result in a major overhaul of the Dutch corporate income tax system. Instead, the focus appears to be on a limited number of technical measures affecting multinational businesses.

Pillar Two and international tax developments
The government is expected to introduce additional safe harbour rules within the Dutch Pillar Two framework. These rules should provide multinational groups with further practical guidance and may help reduce administrative complexity.

In addition, technical amendments are expected in relation to recent Dutch Supreme Court case law, including:
•    the treatment of foreign exchange results on participation hedges; and
•    the abolition of the three-year anti-abuse period in the Dutch merger and demerger facilities.

Employers, Talent & Mobility

Several measures are expected to affect mobility policies, employee remuneration and employment costs.

International mobility
The reduction of the expatriate scheme from 30% to 27% from 1 January 2027 has already been enacted. Higher salary thresholds will also apply to the expatriate scheme.

Company cars
A key expected measure is a 12% pseudo-final levy for employers on fossil-fuel company cars made available to employees from 1 January 2027. The levy will be calculated on the car's catalogue value and is expected to significantly increase the cost of offering non-electric company cars. Additional measures under consideration include:
•    Transitional rules for company cars already made available before 1 January 2027;
•    The future of the youngtimer regime, including a possible phased transition to the previously announced 25-year threshold; and
•    A potential greentimer incentive for electric vehicles between five and eight years old.

Employee remuneration
Further changes are expected to the work-related costs scheme (WKR). While the increase of the first bracket to 2.16% from 1 January 2027 has already been enacted, the government is reconsidering whether this increase should remain in place following a recent evaluation. Additional proposals currently under consideration include
•    Allowing employers to combine tax-free home-working and travel allowances on the same day;
•    Abolishing the exemption for employee discounts on products from the employer's own business;
•    Introducing a targeted exemption for directors' and officers' liability insurance; 
•    Statutorily codifying and indexing the current €2,400 reasonableness threshold; and
•    formal codification of the increase of the kilometre allowance to €0.25 as of 1 January 2026.

In addition, the government is expected to introduce a freedom contribution (vrijheidsbijdrage) through a limitation of the inflation adjustment of personal income tax brackets in 2027 and 2028.

Start-ups & Scale-ups
For start-ups and scale-ups, a separate share-option regime is expected to reduce the taxable base to 65% of the realised benefit. This results in an effective payroll tax rate of approximately 32%, which is comparable to the tax rate in Box 2, and should make employee share incentives more attractive by lowering both the effective tax burden and the immediate liquidity impact. Importantly, taxation would also be deferred until the moment the shares are sold, rather than when they become tradable.

Real Estate

For real estate investors, the most relevant measure to watch is the proposed reduction of the transfer tax rate for residential investment properties.

Transfer tax
The transfer tax rate for residential properties that are not used as a main residence is expected to decrease from 8% to 7% from 1 January 2027. If confirmed, investors may wish to consider whether planned acquisitions can be postponed until 2027 to benefit from the lower transfer tax rate.

Housing corporations
Additionally, a targeted real estate transfer tax exemption is expected for transactions of residential properties between housing corporations, particularly where real estate is transferred within the regulated social housing sector.

Private clients & Box 3

Box 3 remains high on the political agenda, with continued debate around fairness, feasibility and the transition to an actual return-based system.

Towards a new Box 3 regime
The government continues to work towards the introduction of the actual return-based system from 1 January 2028. Several amendments to the current proposal are under consideration:
•    one-year carry-back loss relief;
•    rollover provisions in specific situations;
•    further technical improvements to the draft legislation.

Rate and threshold
The government is also considering:
•    reducing the Box 3 rate from 36% to 35%;
•    increasing the tax-free result from €1,800 to €1,900.

Longer-term direction
Beyond 2028, the government continues to explore a transition towards a full capital gains tax system. This follows strong domestic and international criticism of the current proposal, under which unrealised capital gains would also be taxed annually. A capital gains tax system would instead tax gains upon realisation.

Estate planning
The government is considering measures to reduce the tax benefits of paper gifts. Current proposals include lowering the required interest rate from 6% to 3% and limiting certain planning opportunities that rely on spreading gifts over multiple years. These changes could affect existing family wealth and succession planning structures.

VAT & Excise Duties

Several sector-specific VAT and excise duty measures are expected, including changes affecting the horticultural sector, a possible extension of reduced fuel duty measures, and additional taxation of sugar-rich products and alcohol-free beverages. While these measures are unlikely to affect all businesses, they may have a direct impact on operating costs and pricing strategies within the food, beverage and consumer goods sectors.

Sustainability & Climate

Sustainability measures are expected to remain part of the Tax Plan, mainly through investment incentives and climate-related compliance.

Investment incentives
The most concrete proposal concerns the Energy Investment Allowance (EIA), which is expected to increase substantially from 40% to 45.5%. If adopted, this would materially improve the tax benefit for businesses investing in qualifying energy-efficient assets. The government is also exploring whether existing investment incentives can be simplified and consolidated.

Climate-related compliance
The Tax Plan is expected to include further climate-related tax measures, including developments around the Dutch CO₂ levy and CBAM. These measures may be relevant for internationally operating businesses with energy-intensive activities or cross-border supply chains.

Looking Ahead

The final proposals will only be published on Prinsjesdag and may still change during the parliamentary process. Even so, the expected measures already give businesses and private clients a useful starting point to identify relevant tax risks, opportunities and timing considerations.

Once the Tax Plan 2027 has been published, we will provide a further update on the final measures and their practical implications. If you would like to discuss how the expected measures may affect your business, investment structure or personal tax position, please feel free to contact us.