2027 Dutch Tax Budget – Summary for Multinationals
2027 Dutch Tax Budget – Summary for Multinationals
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The Dutch government published its Budget Day proposals for 2027 on 15 September 2026. This article highlights the key tax changes affecting internationally operating corporate taxpayers. Previously announced tax measures that are scheduled to take effect on 1 January 2027 are not addressed in this article but will be communicated through other channels, such as the BDO Netherlands website.
The main proposals affecting corporate taxpayers are:
Unless stated otherwise, the proposed measures will enter into force on 1 January 2027.
As BDO, we aim to keep you updated on these developments. Affected taxpayers should consider reviewing their tax positions with their tax advisor. If negatively impacted, taxpayers may want to take steps to mitigate the impact by using, for instance, transitional rules. BDO is here to help assess the impact on your business, and to identify risks and opportunities.
Corporate income tax rates unchanged
The Dutch corporate income tax rates remain unchanged and will be as follows in 2027:
| Where the taxable amount or the taxable Dutch amount exceeds | but does not exceed | the corporate income tax rate is |
0 | EUR 200,000 | 19% |
EUR 200,000 | - | 25.8% |
Extension of the lump-sum arrangement in the innovation box
The innovation box is an optional regime in Dutch corporate income tax under which income from self-developed intangible assets can effectively be taxed at a reduced rate. Determining the amount of that income can result in a high administrative burden. To address this, Dutch taxpayers are given the option to determine the income falling within the innovation box on a lump-sum basis. In that case, the income is set at 25% of the profit, subject to a maximum of EUR 25,000. The maximum applies per year and per taxpayer. The lump-sum arrangement may be applied for three years per intangible asset. The Dutch government proposes to increase the maximum lump-sum amount in the innovation box to EUR 100,000 as of 1 January 2027.
Amendment of the tax treatment of currency results on hedging instruments under the participation exemption
Under the Dutch participation exemption, benefits derived from a qualifying participation are exempt. A qualifying participation requires, for example, an interest of at least 5% in a subsidiary. A benefit arising from the currency risk incurred in respect of the investment in a participation is likewise exempt under the participation exemption. In practice, this currency risk is sometimes hedged, for instance by means of a loan or a forward exchange contract. The currency results realised on a hedging instrument may, upon request and subject to conditions, also fall under the participation exemption. A positive currency result on the hedging instrument is then untaxed, and a negative result on the hedging instrument is then non-deductible. The Dutch government proposes to amend the Dutch tax treatment of currency results on hedging instruments under the participation exemption as follows. For financial years commencing on or after 1 January 2027, only the ‘unpriced’ currency result of a legal act intended to hedge a currency risk incurred in respect of a participation may be brought under the participation exemption. This means that the ‘priced-in’ currency result on such hedging instruments will by definition be taxable going forward. The priced-in currency result can be determined when the legal act is entered into and relates to the relative weakness or strength of the currency concerned compared to the currency in which the taxpayer calculates its taxable profit (usually the euro). The unpriced currency result is the difference between the expected exchange rate movement at the time the hedging instrument is entered into (the priced-in currency result) and the actual exchange rate movement upon subsequent settlement of the hedging instrument. Alongside this substantive amendment, the Dutch government proposes to supplement and clarify the application of the participation exemption to hedging instruments in a number of respects.
Transitional rules are proposed for existing hedging instruments. As a result, any priced-in benefit attributable to the period before the first financial year commencing on or after 1 January 2027 remains exempt under the participation exemption, even if that benefit only has to be recognised after that period under the tax rules. At the same time, another transitional measure blocks anticipatory behaviour by taxpayers.
Abolition of the ‘presumption of non-business motives’ as part of the anti-abuse provision for business mergers and demergers
Dutch corporate income tax contains roll-over facilities for mergers and demergers. Under these facilities, immediate corporate income taxation upon the merger or demerger is avoided (as far as possible) and the tax claim is passed on to the acquiring party or parties. Currently a condition is that the merger or demerger is not predominantly aimed at avoiding or deferring taxation (the anti-abuse provision). If certain shares are transferred to a genuine third party within three years of the business merger or demerger, business motives are presumed to be absent (the presumption of non-business motives). It is then up to the taxpayer to provide evidence to the contrary. If the taxpayer fails to do so, ‘abuse’ is deemed to be present. In early 2026, the Dutch Supreme Court ruled that the presumption of non-business motives is contrary to the EU Merger Directive. The Dutch government therefore proposes to abolish this presumption as of 1 January 2027. At the same time, the option for taxpayers to obtain advance certainty that there is no ‘abuse’, despite an intended transfer of shares within the meaning of the presumption, will also disappear.
Increase in the deduction percentage of the energy investment allowance
The purpose of the Dutch energy investment allowance (EIA) is to encourage investment in designated energy-saving business assets. The deduction percentage of the EIA will be increased from 40% to 45.5% as of 1 January 2027. This makes it even more financially attractive for businesses to invest in energy-saving measures or sustainable energy.
Dividend withholding tax refund scheme for domestic round-trip investors
Individuals resident in the Netherlands or entities established in the Netherlands that receive dividends originating from the Netherlands (‘Dutch dividends’) through a foreign investment institution are also referred to as Dutch underlying investors or round-trip investors. In 2024 the Dutch Supreme Court ruled that, under EU law, these Dutch dividends may not be taxed more heavily in economic terms at the level of those investors than if they had invested through a Dutch fiscal investment institution. A Dutch fiscal investment institution is able to deduct the Dutch dividend withholding tax levied from its own Dutch dividend withholding tax payable, whereas a foreign investment institution does not have that option. In response to this judgment, it is proposed to lay down a refund scheme for these Dutch dividends in the Dutch Dividend Withholding Tax Act. The scheme will take effect on 1 January 2027. For earlier years, reliance may be placed on the judgment, subject to conditions. The refund must be applied for with the Dutch tax authorities and is in principle calculated using a fixed calculation method (formula). If it is demonstrated that the actual tax burden is higher than the amount resulting from the fixed calculation method, this may be reclaimed instead. A condition is that the investor is the beneficial owner of the dividend. Additional conditions and limitations to the refund apply to Dutch entities.
Codification of safe harbour rules
The Minimum Tax Act 2024 (Safe Harbour Rules) Bill implements the internationally agreed ‘Side-by-Side package’ in the Dutch Minimum Tax Act 2024 (Pillar Two), which applies to multinational groups and large-scale domestic groups with consolidated revenue of at least EUR 750 million. The bill codifies four safe harbour rules and extends an existing arrangement:
In practice, this means that compliance obligations relating to the Dutch minimum tax may be eased in certain respects, but that it must be assessed for each jurisdiction whether the conditions are met. The qualified domestic minimum top-up tax (‘QDMTT’) continues to apply in full, so a complete calculation may still be required for Dutch group entities. The bill forms part of the 2027 Dutch Tax Budget package and enters into force on 1 January 2027, with certain provisions having retroactive effect to 1 January 2026 and 31 December 2025 respectively, applying for the first time to reporting years commencing on or after those dates.
Bill on tax incentives for start-ups and scale-ups
This bill provides for a lower Dutch wage tax charge on income from share options for employees of start-ups and scale-ups, as well as a deferral of that taxation until the moment the employee sells the shares acquired.
Start-ups and scale-ups often lack the financial resources to offer a competitive salary. A share option plan is an attractive alternative form of remuneration for attracting and retaining talented staff. Under the bill, income from share option plans will, subject to conditions, be taken into account as wages for (only) 65% at the level of the employee. As a result of this narrowing of the tax base, the top Dutch wage tax rate of 49.5% is reduced to approximately 32%.
The bill aims to bring Dutch taxation of share options in start-ups and scale-ups more into line with the international standard.
Reduction of real estate transfer tax from 8% to 7% for second homes
The Dutch real estate transfer tax rate for residential properties in which the acquirer will not live on a long-term basis will be reduced from 8% to 7% as of 1 January 2027. This applies, for example, to the purchase of a property intended for letting or for use as a holiday home. This reduction was already announced in the coalition agreement. For other immovable property, and therefore also for the so-called ‘owner-occupied home’ (main residence), the rate remains unchanged.
Would you like to know what these plans specifically mean for your situation? If so, please contact your BDO advisor.