Key tax tips for business and trade

The tips are based on the Tax Plan 2027 as announced by the Dutch government on Budget Day. The Dutch House of Representatives and the Dutch Senate still have to vote on the Tax Plan 2027.   

Dividend payments  

The government announced a proposal to lower the highest box 2 income tax rate for dividend payments from 31 to 29 per cent as of 1 January 2027. During 2026, this rate applies to incomes above € 8,843 (€137,686 for tax partners). The lower box 2 rate of 24.5 per cent (for incomes up to €68,843 / €137,686) may possibly be reduced to 23.5 per cent. If you are considering a dividend payment that exceeds the first bracket, you may consider spreading this dividend payment over 2026 and 2027 in order to take advantage of the low rate in 2026 and 2027 or to wait until 2027. Please note that dividend payments may also affect the amount of your general income tax credit and elderly income tax credit. 

Charitable donations from own company  

If you make a donation from a private limited company (BV) to a charitable organization (a public benefit organization - ‘ANBI’, or a support foundation for socially beneficial organizations - ‘SBBI’) without a business motive, the donation will be classified as a taxable dividend payment to the shareholder. This donation will only be treated as a taxable dividend payment if it exceeds the maximum gift deduction in corporation's income tax return (this amounts to a maximum of 50 per cent of the profit, with a maximum of € 100,000).    

Application of small-scale investment deduction  

When determining a company's profits, an additional deduction may be claimed for certain investments. This is the small-scale investment deduction (‘kleinschaligheidsinvesteringsaftrek’ or ‘KIA’). In 2026, the KIA applies to total investments between €2,901 and €398,236; the KIA cannot be applied if €398,236 is exceeded. You can consider postponing the investment until 2027 to use the KIA.  

Timely reinvestment in case of reinvestment reserve  

Under conditions, the book profit of an asset may be carried forward to a reinvestment. If a reinvestment reserve was formed within your company in 2023, it is important to make a new investment (that meets the conditions) by the end of 2026 at the latest (to use the formed reinvestment reserve in time). Otherwise, the reinvestment reserve will be released taxed, unless the nature of the asset requires a longer period, or the acquisition has been delayed due to special circumstances.

Terminating a fiscal unity  

In 2026, the corporate tax rate is 19 per cent on the first €200,000 of profit and 25.8 per cent on the excess. By terminating a fiscal unity (for corporate income tax purposes) or demerging an existing company, the first bracket can be used more than once if the combined level of profits exceeds € 200,000. Consider carefully whether terminating the fiscal unity or demerging a company is possible without triggering taxation. Individual circumstances will determine this. If you want to exclude a company from an existing fiscal unity as of 1 January 2027, you should submit a request to the Dutch Tax Authorities by 31 December 2026. 

Submit WBSO application on time 

If a company carries out research and development ('R&D’) activities, it may be eligible for the Research and Development (Promotion) Act (‘Wet bevordering speur- en ontwikkelingswerk’ or ‘WBSO’). The WBSO reduces the costs associated with qualifying innovative activities by providing a reduction in the payable payroll taxes. The amount of the benefit depends, among other things, on the number of hours spent on R&D activities and the related costs and expenditure. 

The main WBSO parameters will remain unchanged in 2027. However, the notional hourly wage for R&D activities will increase from €29 to €33. A WBSO application must be submitted in advance. If you wish to benefit from the WBSO as from 1 January 2027, make sure that the application is submitted on time.  

Lower real estate transfer tax rate for non-residents 

If your organisation is considering purchasing a property (for example to rent out), it is important to bear in mind the real estate transfer tax rate. The 2027 Tax Plan proposes to reduce the rate for properties in which the buyer will not live themselves from 8 per cent to 7 per cent with effect from 1 January 2027. If it is possible to defer the transfer of the property until 2027, you may be able to save on real estate transfer tax.

VAT input tax adjustment for (partly) VAT-exempt entrepreneurs    

Annually, the pro rata percentage must be determined if both VAT exempt and VAT taxed services are performed. If this percentage differs from the originally deducted input VAT percentage, a year-end correction must be made. In addition, an assessment must be made whether a revision of input VAT on investment goods and/or on certain investment services relating to immovable property is necessary. Should the pro rata percentage be lower than 90 per cent, this may also have consequences if parties have opted for a VAT taxed rental of one or more properties. 

Filing a supplementary VAT return     

If you have reported too much or too little VAT in the past financial year or the five previous financial years, you are obliged to correct this via a supplementary VAT return if the correction amount exceeds €1,000 per VAT period. If the correction amount is lower than this threshold amount, you can include the correction in the next VAT return. The supplementary VAT return must be submitted no later than eight weeks after discovering the error with respect to the incorrect VAT reporting. 

Bad debts and VAT   

The year-end is an appropriate time to have insight of outstanding receivables for (potential) bad debts. VAT on uncollectible receivables can be reclaimed via the VAT return as soon as it is certain that all or part of the receivables will no longer be paid. In any case, receivables are deemed uncollectible for VAT purposes after the expiry of one year from the final payment date of the relevant receivable. It is important to actively monitor this period. Note that it is important to correct the VAT payment in a timely manner, as this may be refused by the Dutch Tax Authorities at a later stage. This means that a refund should be requested in the same period in which debt is established as irrecoverable.

Assessing turnover threshold for small entrepreneur scheme   

VAT entrepreneurs who achieve an annual turnover of up to €20,000 can make use of the small entrepreneurs' scheme (‘kleineondernemersregeling’ or ‘KOR’). VAT entrepreneurs applying the KOR do not charge VAT and are not entitled to deduct input VAT. Since 1 January 2025, a VAT entrepreneur can deregister from the KOR at any time. After deregistering the KOR, the scheme cannot be applied again for the remainder of the calendar year in which the entrepreneur deregisters, and the following calendar year. Participation in the KOR for foreign entrepreneurs ends. 
 
In addition, the European KOR had entered into force from 1 January 2025. KOR entrepreneurs can apply the KOR in other EU Member States. The European KOR applies to VAT entrepreneurs established within the EU, but outside the Netherlands, who generate an annual turnover within the EU amounting to no more than € 100,000. 

VAT in the Digital Age 

VAT in the Digital Age (‘ViDA’) introduces new EU requirements for e-invoicing and digital reporting. From 1 July 2030, e-invoicing will become mandatory for both intra-community and domestic B2B transactions. E-invoices must be issued, sent, and received in a structured format. A PDF invoice sent by email will no longer be sufficient. In addition, invoice data for intra-community transactions must be reported digitally on a near real-time basis from 1 July 2030. Although 2030 may still seem far, significant adjustments to invoicing processes and IT systems are required. Make sure to assess the impact of ViDA on your business processes and systems at timely. 

Reclaiming foreign VAT (EU and the United Kingdom)     

When foreign VAT is charged, the VAT cannot be reclaimed in the Dutch VAT return. Instead, a VAT refund request to reclaim the EU VAT can be submitted under conditions to the Dutch Tax Authorities. The VAT refund request must be submitted to the Dutch Tax Authorities no later than 30 September of the calendar year following the refund period. Has the 15-day deadline to forward the refund request to the country of refund expired? In that case, you may be eligible for goodwill interest (‘coulancerente’).  
 
A different deadline and procedure apply for reclaiming VAT from the United Kingdom. The period over which VAT can be reclaimed runs from 1 July 2025 to 30 June 2026 and the refund request must be submitted to the UK Tax Authorities. It is therefore not possible to submit this refund request through the Dutch Tax Authorities. VAT from this period can be reclaimed no later than 31 December 2026.   

CbC Report or notification to Dutch Tax Authorities  

Based on mandatory transfer pricing documentation obligations, Country-by-Country Reporting obligations have been applied since 2016 for groups with consolidated turnover of at least €750 million. If the parent company is based in the Netherlands, it must (in principle) submit a Country-by-Country Report (‘CbCR’) to the Dutch Tax Authorities within twelve months of the end of the group's financial year. If the CbCR is filed by a foreign group company with a foreign tax authority, the Dutch group company must submit a notification to the Dutch Tax Authorities. The notification shows which group company will file the CbCR in which country. This notification must be made to the Dutch Tax Authorities within twelve months after the end of the financial year (often no later than 31 December of the year). 

Public Country-by-Country Reporting   

Due to new legislation, companies with a global consolidated turnover of at least €750 million are required to publish a statement showing the profit taxes paid per EU Member State. This Public Country-by-Country Reporting is based on an EU Directive. The obligation starts for the financial year beginning on or after 22 June 2024. For groups whose financial year equals the calendar year, 2025 is the first reporting year; the report must be published within twelve months of the balance sheet date, i.e. by 31 December 2026. 

 Exchange of information fordigital platforms 

The European DAC7 directive (‘DAC7’) deals with the automatic information exchange for digital platform operators. From 1 January 2023, European digital platforms are obliged to collect and record data on sellers using these platforms. Digital platforms are obliged to report this data to the tax authorities. National tax authorities subsequently exchange this data with other EU Member States. The sales covered by DAC7 are sales of goods, rental of real estate, provision of personal services and rental of means of transport. For the sale of goods, a threshold applies to the reporting requirement: platforms only need to report on sellers who make 30 or more sales in a calendar year for a total amount exceeding €2,000. 
 
The required reporting data must be collected and verified by 31 December of the calendar year to which the data relates. The deadline for reporting the data to the Dutch Tax Authorities is one month later. Therefore, make sure that you meet your DAC7 obligations before the end of the calendar year. 

CBAM compliance 

The Carbon Border Adjustment Mechanism ('CBAM’) seeks to put a price on the embedded carbon emissions of certain goods imported into the EU. As of 1 January 2026, CBAM has fully entered into force. Following this entry into force, importers of CBAM goods or their indirect customs representative (if surpassing the annual threshold of importing more than 50 metric tones of CBAM goods) have a few obligations: 

• From 1 January 2026, they must hold an authorization as an authorized CBAM declarant. If this is not in place, goods can be blocked at the border and penalties can be imposed.  
• From 2027, CBAM importers must submit an annual CBAM declaration, purchase CBAM certificates on a quarterly basis, and when submitting the annual CBAM declaration they must present CBAM certificates.  
• In order to calculate the CBAM emissions, they can either use the default values (which are generally so high that this if effectually a penalty), or actual emission values.  
• If actual values are used, then these must be verified by a third-party accredited verifier.  

Considering that CBAM certificates need to already be purchased on a quarterly basis from 2027 onwards and the fact that there are currently not many accredited third-party verifiers, the Dutch state secretary of Finance has decided that importers are allowed to use unverified actual values in the first half of 2027 to determine the number of certificates to be purchased. 

It is important for CBAM importers (or their indirect customs representatives) to have a clear view on their CBAM authorized declarant status, emission calculation, CBAM certificate purchase and third-party verification strategy. 

New Union Customs Code 

On 19 September 2026, the new Union Customs Code (nUCC) was published. The nUCC introduces important changes for businesses importing goods into the EU. Amongst which the most important are: 

• The introduction of a European Customs Authority. 
• A centralized customs data hub in which data will eventually replace the import declaration. Additionally, all fragmented current systems will be integrated. 
• More focus will be on the regulatory aspects of imports and exports. 
• Online marketplaces and electronic platforms will also become subject to customs responsibilities.  
• The exemption from import duties for consignments with an intrinsic value of up to €150 was abolished as of 1 July 2026. Additionally, until 1 July 2028, a fixed customs duty of €3 per item category applies to such consignments. And lastly, a processing fee of (presumably) €2 will apply to all consignments from outside the EU from mid-November 2026.  
• The AEO regime will be supplemented with the trust-and-check trader regime. 

Until the Union Custom Code ('UCC’) is abolished, both the UCC and the nUCC will apply. The nUCC will enter into force in phases. The e-commerce data needs to be submitted in the Datahub starting in July 2028, for other importers this obligation starts in March 2034. 
 
For internationally active businesses, the nUCC may result in faster and more uniform customs clearance, but also in more intensive supervision. There will be a shift from declaration controls to data driven controls. At the same time, importers, including importers involved in distance sales, will have greater responsibility for compliance with fiscal and non-fiscal import requirements. Businesses are therefore advised to assess in a timely manner whether their customs processes are adequately prepared for these changes.

Document of loan agreements with your bv 

Ensure that all loans with your BV (loans and current account) are documented in writing. This applies to all agreements you have with your BV or agreements between your BVs. Also check the excessive borrowing rules: debts to your BV exceeding €500,000 on 31 December 2026 are taxed in box 2. The government has proposed to lower this threshold gradually from the end of 2027. 

Want to know more about the above year-end tips?  

Would you like to know more about any subject from these year-end tips? Your Forvis Mazars tax advisor is more than happy to assist you further.