Tuesday 15 September 2026 was Prinsjesdag – Dutch Budget Day 2026 – on which the (minority) Jetten I administration presented its tax and budget plans, and State Secretary for Taxation Eelco Eerenberg handed over the well-known briefcase (‘koffertje’) containing the 2027 Tax Plan (Belastingplan 2027). A key point of attention is the legislative proposal on tax incentives for startups and scale-ups, which introduces a new option regime. It also lays down a new definition of startups and scale-ups.
The much-discussed Box 3 file (the Dutch tax on income from savings and investments) has been put ‘on hold’ by the coalition in the Senate. Final decision-making has been postponed by six months to the Spring Memorandum (Voorjaarsnota). – We will of course keep you posted!
If you would like to revisit our Webinar, here it is:
Below, we have set out an overview of the relevant tax changes arising from the 2027 Tax Plan:
VAT and Real Estate Transfer Tax
| ITEM | CURRENT | NEW |
| Abolition of the reduced VAT rate for ornamental horticulture and hot-air balloon flights | Ornamental horticultural products (flowers, plants, flower bulbs, Christmas trees, etc.) and hot-air balloon flights were subject to the reduced VAT rate of 9%. | As of 1 January 2028, the standard rate of 21% applies. |
| New transfer tax exemption for housing associations | The existing exemption for transfers of statutory tasks often made it complex or impossible for housing associations to transfer social housing among themselves without incurring real estate transfer tax. | A new, targeted exemption will be introduced for transfers of DAEB property (social housing qualifying as a service of general economic interest) between housing associations. |
Excise Duties and Consumption Taxes
| ITEM | CURRENT | NEW |
| Refund scheme for bio-based and renewable fuels | A partial excise duty refund compensated for the lower energy content of bio-based and renewable fuels — the scheme was barely used. | The refund scheme will be abolished. |
| Indexation of alcohol excise duty | Alcohol excise duty was not automatically indexed each year. | As of 1 January 2027, alcohol excise duty will be indexed annually in line with the statutory inflation adjustment factor (tabelcorrectiefactor). |
| Abolition of the small brewers’ scheme | Small, independent breweries (up to 200,000 hectolitres per year) paid a reduced rate of excise duty. | Following a negative evaluation, this scheme will be abolished as of 1 January 2028. |
| Extension of the excise duty reduction on petrol and diesel | The temporary excise duty reduction on petrol and diesel ran until 1 January 2027, after which rates would revert to the indexed baseline. | The reduction will be extended until 1 January 2028 and the rates will be phased out more gradually than previously envisaged. |
Business Taxes
| ITEM | CURRENT | NEW |
| Youngtimer scheme (older company cars) | The age threshold for the youngtimer scheme (private-use addition to taxable wage based on the car’s fair market value instead of its list price) was raised from 15 to 16 years as of 2026; under earlier legislation it would rise further to 25 years as of 2027. | Instead, the age threshold will be set at 17 years as of 2027 and structurally at 20 years as of 2028. In addition, extra transitional relief for 2027 will apply to users who were already applying the scheme in 2025. |
| Tax-free travel allowance | The specifically exempt travel allowance for wage tax purposes was € 0.23 per kilometre. | The amount will increase to € 0.25 per kilometre (with retroactive effect to 1 January 2026). |
| Abolition of the exemption for in-house products under the work-related costs scheme (‘WKR’) | Employers may grant employees a tax-free staff discount of 20% on products from their own line of business, up to a maximum of € 500 per year, under a specific exemption within the work-related costs scheme. | This exemption will be abolished. The discount may still be granted tax-free, but charged against the general discretionary allowance (vrije ruimte). |
| Increase in the deduction percentage of the energy investment allowance (‘EIA’) | The EIA deduction percentage was lower than the level proposed for 2027. | The EIA percentage will increase to 45.5% as of 1 January 2027. |
Climate and Emissions-based Taxes
| ITEM | CURRENT | NEW |
| Waste tax & industrial CO2 levy (waste incineration plants) | The 2026 Tax Plan provided for an increasing high rate in the waste tax and a more rapidly tightened CO2 rate for waste incineration plants. | Both trajectories will be slowed down to give the sector more time to make its operations more sustainable. |
| Energy tax for greenhouse horticulture | The reduced energy tax rates for greenhouse horticulture were being phased down towards full elimination in 2035. | For 2027, the rates will be adjusted to compensate for the additional cost of the new green gas blending obligation. |
| Tax on mains water | The rate was € 0.437 per m³ of mains water supplied. | As of 2027 the rate will increase to € 0.537 per m³ (+ € 0.10). |
| Air passenger tax — high rate | As of 2027, a higher rate would apply to long-haul flights under the Air Passenger Tax Differentiation Act. | The high rate will be reduced to the level of the German high rate (€ 59.43), in order to create a more level European playing field. |
| Temporary reduction of motor vehicle tax (MRB) for vans and trucks | The regular MRB rate applied in full to entrepreneurs’ vans and trucks. | As part of the ‘energy shock resilience’ package, a 50% lower rate applies to vans and a nil rate to trucks from 1 July up to and including 31 December 2026. |
For Startups and Scaleups:
| ITEM | CURRENT | NEW |
| New share option regime | The full benefit from share option rights is taxed in Box 1 at the progressive rate (up to 49.5%), in principle at the moment the shares become tradable — often before the employee is able to sell them. | For startups and scale-ups recognised by the RVO (the Netherlands Enterprise Agency), the taxable base will be narrowed to 65% of the benefit and, as a general rule, taxation will be deferred until the shares are actually sold. Intended effective date: 1 January 2027, with retroactive effect to 17 April 2025 for options not yet taxed. (For more in-depth analysis, see our article: ‘De Nieuwe Aandelenoptieregeling’) |
| New definition of startup & scale-up (Article 10ba Dutch Wage Tax Act) | There was no separate tax definition of a startup and/or scale-up. | A single definition will apply to both concepts: ‘an enterprise focused on rapid growth through a scalable and repeatable business model arising from innovation, not listed on a stock exchange and not more than 25% held by a listed entity.’The RVO issues a formal decision on this, valid for 8 years (extendable up to 3 times by 5 years). |
| Broadening of the flat-rate innovation box regime | The maximum flat-rate amount in the innovation box was € 25,000 (unchanged since 2013). | As of 1 January 2027, the maximum will increase to € 100,000, enabling more companies with self-developed IP to apply the innovation box without an extensive calculation. |
M&A and International Tax
| ITEM | CURRENT | NEW |
| Business merger and demerger facility — presumption of non-commercial motive | A reorganisation was presumed by law to be tax-driven (and therefore not to qualify) if shares were disposed of within three years of the merger or demerger; the taxpayer had to rebut that presumption. | Following the Dutch Supreme Court ruling of 27 February 2026 (conflict with the EU Merger Directive), this evidentiary presumption will be deleted. The burden of proof shifts from the taxpayer to the tax inspector. |
| Participation exemption — currency results | Financing costs on hedging instruments were deductible, while the corresponding priced-in (expected) currency result was exempt under the participation exemption — an imbalance. | The priced-in currency result will henceforth be taxable, with transitional relief for existing positions. |
| Safe harbour rules under the Minimum Taxation Act 2024 (Pillar Two) | Groups within the scope of the Minimum Taxation Act 2024 always had to calculate the top-up tax in full, even in low-risk situations. | Following the Side-by-Side agreement (OECD Inclusive Framework, 5 January 2026), six safe harbour rules will be introduced — including a simplified ETR safe harbour, a safe harbour for a qualifying equivalent minimum taxation system, a UPE safe harbour, a safe harbour for qualifying tax incentive regimes, an extension of the temporary CbCR safe harbour and a technical adjustment for a 52/53-week reporting year — which set the top-up tax at nil in specific situations and thereby limit administrative burdens. Retroactive effect to 31-12-2025 or 1-1-2026, depending on the rule. |
