Can I Claim Interest on Business Loans (Rentelasten) as a Business Expense in Netherlands?
Interest on business loans is deductible for Dutch VPB, subject to the earnings-stripping rule: net interest expense is limited to the higher of 20% of fiscal EBITDA or EUR 1 million. For most Dutch SMEs, the EUR 1 million threshold means the restriction rarely applies. Related-party interest may face additional restrictions under Article 10a Vpb.
What Belastingdienst (Dutch Tax and Customs Administration) says
Wet VPB 1969 Art. 15b: earnings-stripping rule (ATAD) — net interest limited to higher of 20% EBITDA or EUR 1 million. Art. 10a Vpb: anti-avoidance for related-party interest on tainted transactions. Disallowed interest carries forward indefinitely.
When you can claim
- Interest on bank loans, invoice financing, asset finance, and lease finance from unrelated lenders
- Net interest below EUR 1 million per year — fully deductible for most Dutch SMEs without an earnings-stripping test
- Bank arrangement fees and commitment fees on genuine commercial lending
When you cannot claim
- Net interest exceeding both EUR 1 million and 20% of fiscal EBITDA under the earnings-stripping rule
- Related-party interest under Art. 10a Vpb where the loan funds a capital contribution, acquisition of a related entity, or dividend to a related party, without commercial rationale
- BTW on interest payments — interest is BTW-exempt, so no input BTW is available
Good to know
Pro tip: Track the carry-forward of any disallowed interest each year. There is no time limit on the carry-forward. When EBITDA improves in a future year and creates headroom, the carried-forward interest becomes deductible at that point.
Important: For BVs with significant intra-group lending, the Art. 10a anti-avoidance rules are separate from earnings-stripping and can deny the deduction entirely. Always document the commercial rationale for intra-group loans with a proper loan agreement and arm's-length interest rate.
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