September 28th, 2026
The Dutch Tax Plan 2027 package contains several targeted changes relevant to Dutch companies and international groups. The package consists of four bills. The measures discussed below are spread across the main Tax Plan bill, the Other Fiscal Measures bill and a separate bill on safe-harbour rules under the Minimum Tax Act 2024.
The proposals cover energy-efficient investments, the innovation box, currency hedges, reorganisations, investment funds, residential property and Pillar Two. Most are intended to take effect on 1 January 2027, although specific commencement and transitional rules apply.
Higher deduction for energy-efficient investments
The Energy Investment Allowance (EIA) allows a business to deduct part of the cost of designated energy-efficient assets from its taxable profit, in addition to regular tax depreciation. The proposal increases this additional deduction from 40% to 45.5% of the qualifying investment amount from 1 January 2027.
This increases the tax benefit for qualifying investments. Companies planning energy-saving or sustainable-energy investments should check whether the asset and investment meet the applicable EIA conditions.
More accessible innovation box for smaller companies
Companies with qualifying self-developed intangible assets may use the innovation box, under which qualifying profits are effectively taxed at a reduced corporate income tax rate. A simplified method is available to reduce the administrative burden of determining the qualifying profit.
Under the optional simplified method, 25% of the taxpayer’s profit is deemed innovation box income, capped at €25,000 per year and taxpayer. The proposal raises the cap to €100,000 from 1 January 2027, while the percentage remains 25%.
The method applies in the year the intangible asset arises and the following two years. The higher cap may make it more useful for smaller innovative companies for which a full calculation is too costly or time-consuming.
Participation exemption and currency hedges
The Dutch participation exemption generally keeps returns from a qualifying shareholding outside the Dutch corporate income tax base. Dividends and gains are usually exempt, while losses are generally not deductible. Currency gains and losses on a foreign-currency participation are generally covered as well.
A company may hedge this currency risk with a foreign-currency loan or derivative. Results on the hedge are normally taxable or deductible, but the company may ask the tax inspector to bring them within the participation exemption.
For financial years starting on or after 1 January 2027, only the non-priced-in result may be covered. Broadly, the priced-in result is the expected currency movement already reflected in the hedge’s pricing, while the non-priced-in result is the difference between that expectation and the actual currency movement.
Taxpayers may also request that the participation exemption cease to apply to future hedge results. Transitional rules cover existing hedges and earlier requests, so groups should review their current arrangements.
Business mergers and demergers
Dutch corporate income tax provides rollover facilities that can defer immediate taxation of gains on qualifying business mergers and demergers. The facilities can be refused if the reorganisation is predominantly aimed at avoiding or deferring tax.
The proposal removes the statutory presumption that valid business reasons are absent when shares in an involved entity are sold to an unrelated party within three years. The tax inspector must first provide evidence indicating that commercial reasons may be absent or that the transaction may be aimed at tax avoidance or deferral.
The anti-abuse test itself remains. Companies considering a reorganisation followed by a sale should therefore continue to document the commercial reasons for the transaction.
Dividend tax refund for investors in foreign funds
When a Dutch company distributes a dividend to a foreign investment fund, Dutch dividend withholding tax may be withheld from the distribution to the fund. To the extent that the fund cannot obtain relief, this reduces the amount available for distribution to its investors. Following a 2024 Supreme Court judgment, Dutch-resident investors in the fund may in certain cases request a refund under EU law for the portion of the Dutch dividend tax economically attributable to them. The proposal introduces a statutory refund mechanism and calculation method for such investors, subject to conditions.
For Dutch resident entities, the annual refund is capped at the corporate income tax payable for the relevant year. Any refund not granted because of this cap may be carried forward to later years. The mechanism is proposed to apply to Dutch dividend tax withheld from 1 January 2027 and is intended to align the treatment with comparable investors using a Dutch fiscal investment institution.
Transfer tax changes for residential property
The transfer tax rate for homes that will not be used by the buyer as a main residence is proposed to decrease from 8% to 7% on 1 January 2027. This includes rental homes acquired by corporate investors.
Offices, commercial buildings and other non-residential real estate continue to fall under the general 10.4% rate. Companies planning residential property acquisitions should take the proposed rate change into account.
A new exemption is proposed for qualifying property transfers between housing associations admitted under the Dutch Housing Act. The transferring association must have used the property immediately before the transfer for qualifying services of general economic interest (DAEB), such as social or student housing and certain residential care properties. Property not used for these qualifying services does not fall within the proposed exemption.
Pillar Two safe harbours
Broadly, the Dutch Minimum Tax Act 2024 applies to multinational and certain domestic groups with consolidated annual revenue of at least €750 million. It generally targets an effective tax rate of at least 15% in each jurisdiction. A separate bill within the Tax Plan 2027 package implements the international Side-by-Side package. If its conditions are met, a safe harbour can simplify the calculation or limit the application of the top-up tax rules.
The four new safe harbours are the Simplified Effective Tax Rate (ETR), Side-by-Side, Ultimate Parent Entity (UPE) and Substance-based Tax Incentive Safe Harbours. The bill also extends the transitional Country-by-Country Reporting Safe Harbour by one year, allowing it for financial years beginning on or before 31 December 2027 and ending before 1 July 2029.
The bill is proposed to enter into force on 1 January 2027. The Simplified ETR Safe Harbour may apply to financial years beginning on or after 31 December 2025, subject to conditions, while the other three new safe harbours are proposed to have retroactive effect to 1 January 2026.
What should companies and international groups do?
Companies should identify which proposals affect planned investments, innovation, reorganisations, currency hedges, fund holdings or residential property transactions, and confirm the relevant conditions and effective dates.
Groups within the scope of Pillar Two should separately assess available safe harbours, data requirements and elections by jurisdiction.
These proposals are subject to parliamentary approval and may change. Contact Broadstreet to discuss their impact on your company or group.
