Budget Day 2026: measures for business and trade
On Budget Day 2026, the plans for the coming year were announced. We have listed the most important tax measures aimed at businesses and trade, both nationally and internationally, for you. What changes for you?
- Increase energy investment allowance: The energy investment allowance rate will be increased from 40 per cent to 45.5 per cent.
- Reduction and abolition of a relief for new self-employed entrepreneurs: The relief for new self-employed entrepreneurs for personal income tax purposes (‘startersaftrek’) will be reduced from € 2,123 to € 10 and will be abolished entirely with effect from 2028. The relief for new self-employed entrepreneurs is an additional deduction, supplementing the self-employed personal allowance that is available to individuals starting a business.
- Reduction and abolition of a relief for new entrepreneurs and occupational disability: The relief for new self-employed entrepreneurs in case of occupational disability ('startersaftrek bij arbeidsongeschiktheid') for personal income tax purposes will be abolished in 2029. This relief is an additional deduction available to individuals starting a business and who are eligible to receive a disability benefit.
- Elimination random depreciation for new entrepreneurs: The tax facility for new self-employed entrepreneurs to depreciate business assets at an accelerated rate will be eliminated from 2028.
- Reduction and abolition business discontinuation relief: The business discontinuation relief for personal income tax purposes (‘stakingsaftrek’) will be reduced from € 3,630 to € 908 and will be abolished entirely as of 2030. The business discontinuation relief is available to entrepreneurs who discontinue their business activities, for example as a result of the sale of their business. As a result of this relief, entrepreneurs pay less personal income tax on part of the profit realized upon the discontinuation of their business.
- Reduction and abolition co-working partner's relief: The co-working partner's relief for personal income tax purposes (‘meewerkaftrek’) will be reduced by 75 per cent and will be abolished entirely as of 2030. As a result, the percentages of business profits that qualify for the deduction will be reduced. The co-working partner's relief is a personal income tax facility that allows entrepreneurs whose partner works unpaid in their business to reduce their taxable profit and, consequently, their personal income tax liability.
- Increase of deductible travel expenses: The maximum travel expense deduction for business owners for income tax purposes (and individuals receiving income from other activities) will be permanently increased retroactively, effective 1 January 2026, from € 0.23 to € 0.25 per kilometre. Although this increase had already been introduced stipulated in an administrative decree, and it is now being included in legislation.
- Introduction of freedom contribution: A so-called freedom contribution has been introduced for both individuals and businesses. The contribution will be implemented through a limitation of the inflation adjustment of personal income tax brackets and tax credits, as well as an increase in the employer contribution to the Disability Insurance Fund ('Arbeidsongeschiktheidsfonds'). As a result, the overall tax and social security burden will gradually increase, without an increase in the statutory tax rates.
- Expansion of innovation box flat-rate scheme: Under corporate income tax rules, the innovation box flat-rate scheme is being expanded. Under the innovation box, profits that companies generate from innovative activities are taxed at a lower effective rate (9 per cent in 2026), subject to certain conditions. Under the flat-rate scheme, eligible taxpayers may choose to calculate the profit eligible for the innovation box as 25 per cent of taxable income, up to a maximum of € 25,000 euros. This maximum amount will be increased to € 100,000.
- Abolition of presumption of non-businesslike motives for demergers and business mergers – Under certain conditions, companies may implement legal demergers without triggering Dutch corporate income tax. This tax-neutral treatment is unavailable where the transaction is primarily driven by non-commercial motives. Current legislation includes a rebuttable presumption that valid business motives are absent if shares in the demerged or demerging entity are transferred to a third party within three years after the demerger. This statutory presumption will be abolished, as it is considered to be in violation of the EU Merger Directive. The same change will be made to the comparable statutory presumption applicable to business mergers. In addition, the option to obtain advance certainty regarding whether a disposition within three years of the reorganization is intended to avoid or defer taxation is abolished.
- Restriction of participation exemption for foreign exchange results on hedging instruments: Foreign exchange results on certain hedging instruments may, upon request and subject to certain conditions, fall within the scope of the participation exemption. For financial years commencing on or after 1 January 2027, only the 'unpriced foreign exchange result' on a hedging instrument used to hedge a currency risk relating to a qualifying participation may benefit from the participation exemption. The priced foreign exchange result will no longer qualify for the participation exemption. For hedging instruments that were already in existence on 1 January 2027, transitional rules apply. In addition, a separate deferred-effect provision has been introduced for hedging instruments entered into before 15 September 2026 Finally, several formal amendments will be made to this regime.
- Expansion housing associations’ investment capacity: The government has announced that housing corporations will be excluded from the scope of the general interest deduction limitation as of 2028. This change will be introduced through an amendment to the 2027 Tax Plan. This exception provides housing corporations with greater financial flexibility. They will be able to take the change into account in their multi-year budgets, creating additional financing capacity within the guarantee framework of the Social Housing Guarantee Fund (‘Waarborgfonds Sociale Woningbouw’, ‘WSW’). This strengthens the investment capacity of housing corporations and supports the development of new housing and sustainability projects.
- Clarification term public funding in the education and research exemption: In the Dutch corporate income tax there is an exemption for education and research activities. A condition for this exemption is that these activities must be funded primarily from public funds. The legislature has clarified that funding from public funds does not apply if there is a contractual consideration. Remuneration for education or research activities performed for a fee is therefore not covered by the exemption. The amendment is intended to clarify the existing legislation and does not aim to substantively change the current application of the exemption.
- Abolition exemption for income from forestry activities: The forestry exemption for income from forestry activities currently available under both the Dutch personal income tax and corporate income tax regimes will be abolished as of 2029. No transitional provisions apply. Following a negative policy evaluation, the exemption was found to be neither effective nor efficient. As a result, profits derived from forestry activities will become fully subject to personal income tax or corporate income tax, while losses will become deductible.
- Increase VAT rate for ornamental horticulture products: The reduced VAT rate applicable to ornamental horticulture products will be abolished as of 2028. As a result, products such as flower bulbs, cut flowers, plants and nursery stock (including Christmas trees) will become subject to the standard VAT rate of 21 per cent, instead of the current reduced rate of 9 per cent.
- Increase VAT rate for hot-air balloon rides: The reduced VAT rate for hot-air balloon rides will be abolished as of 2028. As a result, the VAT rate for hot-air balloon rides will increase from 9 per cent to the standard VAT rate of 21 per cent.
- Indexation of alcohol excise duties: Excise duty rates on alcoholic beverages will be indexed annually. Unlike fuel excise duties, alcohol excise duties are currently not adjusted each year. The annual indexation is intended to prevent the real value of alcohol excise duties from gradually declining over time as a result of inflation.
- Elimination of small brewers arrangement: The small brewers arrangement will be eliminated effective 2028. This measure provides for a reduced excise duty rate for small brewers.
- Reduction real estate transfer tax for non-owner-occupied residential property: The real estate transfer tax rate applicable to the acquisition of residential property that will not be used as the purchaser’s main residence, such as rental properties or holiday homes, will be reduced from 8 per cent to 7 per cent. This measure is, for example, relevant for real estate investors, developers and social housing associations
- Introduction of real estate transfer tax exemption for social housing associations: Transfers of real estate carried out within the framework of services of general economic interest (SGEI) activities will be exempt from the real estate transfer tax. As a result, housing associations transferring residential properties to one another as part of their social housing activities will no longer be subject to transfer tax.
- New dividend withholding tax refund scheme for Dutch dividends received through foreign investment funds: A dividend withholding tax refund scheme will be introduced for Dutch investors who receive dividends from Dutch resident companies through foreign investment funds. Under this scheme, Dutch investors may, subject to certain conditions, reclaim Dutch dividend withholding tax that was levied at the level of the foreign investment fund. As a result, a Dutch underlying investor holding Dutch shares through a foreign investment fund is not economically taxed more heavily than an investor holding those shares through a Dutch fiscal investment institution.
- Amendments minimum tax Pillar Two rules: The Pillar Two rules will be amended to align with international agreements reached within the OECD Inclusive Framework, including the OECD's Side-by-Side package. The amendments include the introduction of:
(a) the Simplified Effective Tax Rate Safe Harbour for fiscal years commencing on or after 31 December 2025;
(b) the Qualified Equivalent Minimum Tax Regime Safe Harbour;
(c) the Ultimate Parent Entity Safe Harbour; and
(d) the Qualified Refundable Tax Credit Safe Harbour.
In addition, the Transitional Country-by-Country Reporting Safe Harbour will be extended. Finally, the Transitional Undertaxed Profit Rule (UTPR) Safe Harbour for multinational enterprise groups with a 52- or 53-week fiscal year is also addressed. - New Union Customs Code (nUCC): The EU has reached an agreement on the reform of the Union Customs Code (UCC). For businesses, the new rules on distance sales and the introduction of the EU Customs Data Hub are particularly relevant. Until the UCC is withdrawn, the UCC and the nUCC will coexist. The nUCC will enter into force in phases, starting in 2028. The mandatory processing fee for services of customs authorities in connection with distance sales is expected to take effect in mid-November 2026.
- Carbon Border Adjustment Mechanism (CBAM): As of January 2026, the Carbon Border Adjustment Mechanism (CBAM) is fully operational. CBAM aims to prevent carbon leakage by ensuring that the carbon price of imports reflects more accurately the carbon emissions of certain goods imported into the EU. Importers of CBAM goods must obtain the status of authorised CBAM declarant and buy a sufficient number of CBAM certificates corresponding to the embedded emissions of the imported goods. Additionally, compliance with CBAM requirements will be subject to enhanced monitoring and enforcement through the further strengthening of the enforcement powers of the Dutch Emissions Authority (NEa). To facilitate the implementation of CBAM, amendments have been made to the Environmental Management Act. The penalty provision for violations of the core CBAM obligations has also been relaxed, resulting in lower fines being imposed for minor infractions or unintentional violations.
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