Spring Memorandum 2026: tax measures

Individuals 

Adjustment to personal income tax brackets – The first two income tax brackets are being adjusted to compensate for the (expected) lower premium income under the Health Insurance Act. 

Introduction of the freedom contribution – From 2027 onwards, a freedom contribution will be levied on citizens by partially restricting the inflation adjustment of the income tax brackets. 

Abolition of the deduction for specific healthcare costs – The deduction for specific healthcare costs and the allowance for specific healthcare costs will be completely abolished from 2028. 

Reduction in transfer tax for private investors – The transfer tax rate for the purchase of properties that the buyer does not intend to live in themselves (such as a property for letting or a holiday home) will be reduced from 8% to 7% from 2027. 

Abolition of the measure on the valuation of residential properties for gift tax purposes – A measure had previously been announced whereby, from 2027, residential properties would be valued for gift tax purposes based on ‘market value’ rather than the WOZ value. This measure has been abolished.  

Potential tighter rules on gifts on paper – The government has identified ‘gifts on paper’ as a notable tax arrangement. As a possible approach, the government outlines two measures: reducing the interest allowance on gifts on paper from 6% to 3% and introducing notional acquisitions in gift and inheritance tax to remove the progressive tax advantage. 

Potential tighter rules on preferential treatment via loans – The government has classified the transfer of untaxed or low-taxed returns on capital to individuals via loans on non-arm’s-length terms or via non-buisinesslike loans as a notable tax arrangement. The government is therefore examining a measure that would tax the material benefit in the case of loans with non-arm’s length terms and non-businesslike loans. The government considers it desirable that such a measure also provides clarity on the valuation basis in cases where a legal entity (such as a private limited company) is the debtor.

Business and trade 

Introduction of the freedom contribution – A freedom contribution for businesses will be introduced from 2027. The freedom contribution for businesses has been defined as an increase in the AOF (Algemeen Arbeidsongeschiktheidsfonds) contribution (with the same ratio between the low and high rates). Further consultations will take place regarding the details.  

Changes to the minimum tax – Following international agreements within the OECD framework (the Side-by-Side Agreement), the minimum tax (Pillar 2) will be amended.  
Increase in VAT rate for ornamental plant cultivation products – The reduced VAT rate for the supply of ornamental plant cultivation products will be abolished with effect from 2028. As a result, the VAT rate for ornamental plant cultivation products will rise from 9% to the standard VAT rate of 21%. 

Introduction of a sugar tax for producers – From 2030, a tax will be introduced on food products with a sugar content of 6% or more. The tax will apply to pre-packaged products where the sugar content can be read from the label.  

Revision of the excise duty refund scheme for biofuels – The excise duty refund scheme for biofuels will be revised from 2027.  

Expansion of housing associations’ investment capacity – The investment capacity of housing associations will be increased from 2028 via a corporate tax facility.  

Introduction of a transfer tax exemption for housing associations – From 2027, transfers of immovable property within the scope of social activities (Services of General Economic Interest) will be exempt from transfer tax. As a result, housing associations that transfer immovable property (such as dwellings) to one another within the scope of their social housing remit will not pay transfer tax. 

Employers and employees 

Freezing the pension accrual cap – From 2027, the maximum pensionable salary will not be indexed for a period of six years. The ceiling will remain at the 2026 level until 2032, amounting to € 137,800.  

Deferral of lump-sum pension – The introduction of the Lump-Sum Pension Reform Act is being deferred from 1 July 2026 to 1 January 2029.  

Increase in employer contributions – The AOF (Algemeen Arbeidsongeschiktheidsfonds) and AWf (Algemeen Werkloosheidsfonds) contributions will be increased in the coming years to compensate for the (expected) lower contribution income under the Health Insurance Act and the impact of the reduction in the maximum daily wage on employer contributions. 

Energy, climate and mobility 

Extension of excise duty reduction on petrol – The reduction in fuel excise duty on petrol will be extended until 2027 (including). In 2027, the petrol excise duty rates will be kept at the same level as in 2026. 

ETS2 – The ‘Emission Trading System’ (ETS) 2 has been postponed by one year until 2028. 

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