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Reduction of real estate transfer tax for residential property

As part of its housing market agenda, the government proposes to reduce the real estate transfer tax rate for non‑owner‑occupied residential property from 8% to 7% as of 2027. The reduced rate applies to acquisitions of residential property that is not used as a primary residence by the purchaser, such as property intended for rental or use as holiday homes. The measure aims to improve the Dutch investment climate by lowering upfront transaction costs. In practice, the reduced transfer tax may improve entry economics, particularly in the case of larger residential acquisitions.

Corporate income tax facility for housing corporations

The Spring Memorandum further announces a plan to grant Dutch housing corporations additional tax relief to increase their investment capacity. The intention is to create more financial headroom through the corporate income tax system, allowing housing corporations to invest more in affordable housing and sustainability. From 2028, an amount of EUR 250 million per year has been reserved for this purpose, increasing to EUR 325 million on a structural basis by 2032. At this stage, however, it is not yet clear how this tax facility will be designed in practice. Further details are expected to follow in future legislative proposals.

Continued focus on unintended use of earnings stripping rules

While the Spring Memorandum does not introduce new interest deduction measures, it confirms a continued focus on the functioning of the earnings stripping rules and the prevention of unintended use, including the splitting of activities across multiple entities to multiply the threshold. To address such unintended use, the government announces a targeted review of three policy options:

• introducing a group concept for applying the earnings stripping threshold;
• limiting the threshold in cases of excessive group financing; and
• introducing a specific anti‑abuse rule for related‑party debt involving affiliated entities or individuals.

The government aims to inform Parliament of the outcomes of this review before 1 July 2026.