Spring Memorandum 2025: fiscal measures

Individuals

Income tax indexation –The personal income tax (PIT) brackets and tax credits will receive limited inflation compensation from 1 January 2026. The table correction factor will be applied at a rate of 46.2% instead of 100%.

Flat rate of return (box 3) -The flat rate of box 3 of the PIT on the fictitious return on other assets (such as: investment portfolios and second homes) will increase up to 7.78% (1.78 percentage point increase) in 2026.

Tax-free assets (box 3) -The tax free amount in box 3 will be reduced to (approximately) EUR 51,396 per person by 2026. This amount will be finalised at a later date.

Energy tax -The energy tax reduction will be increased. This energy tax reduction is a fixed amount that is deducted from the energy bill and will be increased up to EUR 529.10 in 2026.

Children – For the gift and inheritance tax, it is proposed to treat biological children the same as legal children, hence entitling biological children to the child allowance and the lower tax rate.

Deadline for filing inheritance tax returns - The deadline for filing inheritance tax returns will be extended. The deadline is currently eight months after the passing of the testator.

Estate planning – Currently, married couples are able to amend their prenuptial agreement when anticipating a death to largely avoid inheritance tax. As a measure, it is proposed that if there is a community of property to which both spouses are entitled to for unequal fractions or an "unequal settlement clause", gift or inheritance tax will be levied to the extent that a taxpayer acquires more than 50% on the dissolution of the community or under the settlement clause.

Businesses

VAT rate - The proposed increase in the VAT rate on culture, media and sport to 21% by 2026 will not be implemented.

Business discontinuation deduction - The business discontinuation deduction (in Dutch: stakingsaftrek) for PIT will be reduced to EUR 908 in 2027 and abolished as of 2030. The business discontinuation deduction is a scheme for entrepreneurs who discontinue trading, which means that no income tax is payable on a proportion of the profits from the discontinuation of trading.

Partner contribution deduction - The PIT partner contribution deduction (in Dutch: meewerkaftrek) will be reduced in 2027 and abolished by 2030. The co-employment deduction is a scheme for entrepreneurs whose partner works unpaid in the business, allowing them to pay less income tax on their profits.

Environmental investment - The reserve fund for the Environmental Investment Allowance (in Dutch: MIA) will be increased in 2025. The reserve budget for the random depreciation of environmental investments (in Dutch: Vamil) will be reduced in 2025.

Dairy consumption tax construct - For the consumption tax on non-alcoholic beverages, the “add a small amount of dairy” construct is being addressed. The consumption tax on non-alcoholic beverages has an exception for dairy and soy drinks. Producers add a small amount of dairy to fruit and vegetable juices or soft drinks and, as a result, these drinks fall under the exception for dairy and soy drinks. The proposal is to amend the dairy exception to include sugary dairy drinks under the consumption tax.

Cooperation entrepreneurs and their own private limited company - The government is examining a measure to deny entrepreneurs tax credits in box 1 of their PIT if an entrepreneur enters into a cooperation agreement through their PIT business with their private limited company.

Employers and employees

Employee participation for innovative startups and scale-ups - A tax scheme is being introduced for employees of innovative startups and scale-ups with the aim of encouraging innovative companies and attracting talent. This scheme will lead to a lower tax levy. The scheme is designed in such a way that the basis of income from stock options is narrowed to 65% and the moment of taxation is postponed until the actual sale of the shares.

Company bicycle - The bicycle scheme in payroll tax will be adjusted for bicycles used for business purposes but not parked at home. No additional taxable benefit will apply to such bicycles.

RVU levy - In the Dutch Early Retirement Scheme (in Dutch: Regeling voor Vervroegd Uittreden or RVU), the threshold exemption will be increased from 2026 and extended for three years. In addition, the rate of the RVU levy will be increased in steps up to 65% in 2028.

Aof premiums - Occupational disability contributions (in Dutch: arbeidsongeschiktheidspremies or Aof) will be structurally increased as of 2026. In addition, the low Aof rate will be reduced by 0.21%-point in 2026 and 0.23%-point in 2027 and the high Aof rate will be increased by 0.03%-point in 2026 and 0.04%-point in 2027.

Want to know more about what these tax measures mean for you? Then contact your tax advisor at Forvis Mazars.