What is VPB (Vennootschapsbelasting)?
Vennootschapsbelasting (VPB) is Dutch corporate income tax. The rate is 19% on the first EUR 200,000 of taxable profit and 25.8% above that threshold. BVs, NVs, and most other Dutch legal entities are subject to VPB. The annual return (aangifte vpb) is filed with the Belastingdienst within 5 months of the financial year-end.
Current Rate (Calendar year (1 January to 31 December) in most cases)
19% on first EUR 200,000; 25.8% above EUR 200,000 (2025/2026)
Example
A BV with EUR 300,000 taxable profit pays: 19% x EUR 200,000 = EUR 38,000 plus 25.8% x EUR 100,000 = EUR 25,800. Total VPB: EUR 63,800.
How VPB (Vennootschapsbelasting) works in Netherlands
Vennootschapsbelasting (VPB) is the cornerstone of Dutch business taxation. It applies to the worldwide profits of Dutch-resident companies and the Dutch-source profits of non-resident entities with a permanent establishment in the Netherlands.
**Two-rate structure**
The VPB rates for 2025 and 2026 are: - 19% on taxable profit up to EUR 200,000 - 25.8% on taxable profit above EUR 200,000
The lower bracket was deliberately kept attractive for SMEs and owner-managed BVs. A company with EUR 200,000 profit pays exactly EUR 38,000 in VPB.
**Computing taxable profit**
Taxable profit starts with the company's accounting profit under Dutch GAAP (or IFRS), then adjusted for tax-specific items: - Participation exemption (deelnemingsvrijstelling): dividends and capital gains from qualifying subsidiaries (at least 5% shareholding) are fully exempt - Innovation Box: profits from self-developed qualifying IP are taxed at an effective 9% rate rather than standard VPB rates - Non-deductible costs: excessive remuneration above EUR 650,000, certain fines, 20% of business meal costs - Transfer pricing adjustments for related-party transactions - Fiscal depreciation rules (e.g. buildings can only be depreciated to 100% of WOZ value)
**Fiscal unity (fiscale eenheid)**
A parent BV and its subsidiaries (at least 95% ownership) can form a fiscal unity. This consolidates results so losses in one entity offset profits in another, and intra-group transactions are ignored for VPB. Useful for groups with loss-making subsidiaries.
**Thin capitalisation and earnings-stripping**
Net interest expense (interest paid minus interest received) is only deductible up to 20% of EBITDA or EUR 1 million, whichever is higher. This earnings-stripping rule (ATAD implementation) limits debt-driven structures. Specific anti-avoidance rules also restrict interest on related-party loans used to acquire group entities.
**Filing and payment**
The VPB return (aangifte vpb) must be filed within 5 months of the year-end, typically by 1 June for a 31 December year-end. Extension to 1 November is available on request via the Belastingdienst. The Belastingdienst issues provisional assessments (voorlopige aanslagen) during the year based on estimated profit; companies pay monthly instalments and true up on filing. VPB returns are filed digitally via the Belastingdienst portal.
Related terms
A Besloten Vennootschap (BV) is a Dutch private limited company, the most common corporate structure for entrepreneurs, SMEs, and foreign investors setting up in the Netherlands. Since the 2012 Flex-BV law, minimum share capital is EUR 0.01. The BV is a separate legal entity; its shareholders have limited liability. Shares are not publicly tradeable.
The Innovation Box is a Dutch VPB incentive that taxes profits derived from qualifying self-developed intellectual property at an effective rate of 9% rather than the standard 19% or 25.8% rates. To qualify, the IP must be partly developed in-house and typically supported by a WBSO R&D grant. The regime follows the OECD nexus approach.
The deelnemingsvrijstelling (participation exemption) fully exempts dividends and capital gains received by a Dutch BV or NV from a qualifying subsidiary from Dutch VPB. The shareholding must be at least 5%. This makes the Netherlands one of the world's most attractive holding company jurisdictions, particularly for EU and international groups.
A DGA (Directeur-Grootaandeelhouder) is a company director who holds a substantial interest of at least 5% in that company's shares. Most Dutch BV founders are DGAs. The DGA must receive a customary wage (gebruikelijk loon) from the BV of at least EUR 56,000 per year in 2025, ensuring wage tax is paid before profits are distributed as dividends.
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