Netherlands Tax Changes — Live Tracker

What changed

The lower VPB (vennootschapsbelasting) rate of 19% applies to the first EUR 200,000 of taxable profit. Profits above EUR 200,000 are taxed at 25.8%. The lower bracket threshold was temporarily increased to EUR 395,000 in 2022 but was cut back to EUR 200,000 from 1 January 2023. This reduction means a larger portion of profits is taxed at the higher 25.8% rate for companies with profits between EUR 200,000 and EUR 395,000 compared to 2022.

Who it affects

• BVs and NVs with annual taxable profits above EUR 200,000
• Holding companies
• Subsidiaries of foreign groups
• SMEs incorporated as BV that have grown profitably

What to do

Model your effective VPB rate based on projected profits. For businesses near the EUR 200,000 threshold, consider the timing of deductions and income recognition. Ensure your quarterly VPB provisional assessments (voorlopige aanslag) reflect current year profitability to avoid interest charges on underpayment.

What changed

From 1 January 2024, Box 2 income (dividends and capital gains from substantial shareholdings of 5% or more) is no longer taxed at a flat rate. The first EUR 67,000 of Box 2 income per taxpayer is taxed at 24.5%; amounts above this threshold are taxed at 33%. Fiscal partners can each use the EUR 67,000 lower rate band, effectively doubling the lower-rate amount to EUR 134,000. The previous flat rate of 26.9% has been replaced entirely.

Who it affects

• DGAs (director-major shareholders) receiving dividends from their BV
• Shareholders with substantial interests (5%+) in companies
• Partners splitting dividend income between spouses
• BV owners planning dividend distributions

What to do

Plan dividend distributions carefully across tax years. For smaller annual distributions up to EUR 67,000 per person, the 24.5% rate is more favourable than the old 26.9% flat rate. For larger distributions, the 33% rate on the excess is significantly higher. Consider spreading large retained profits over multiple years with your tax advisor to maximise the lower band.

What changed

The gebruikelijk loon — the minimum salary a BV must pay its DGA (directeur-grootaandeelhouder) — increased sharply from EUR 51,000 in 2023 to EUR 67,000 in 2024. This is the minimum unless the DGA can demonstrate a lower salary is in line with market rates for comparable roles or that the company cannot afford the higher amount. The increase raises payroll tax (loonheffing) and social security costs for many DGAs. The gebruikelijk loon is also the basis for checking against the highest-paid employee rule.

Who it affects

• DGAs of BVs paying themselves a salary
• Holding company directors with operating company employment
• Small BV owners who previously paid below EUR 67,000
• Payroll administrators processing DGA salaries

What to do

Review your current DGA salary against the EUR 67,000 threshold. If you are paying less, either increase the salary or document why the lower amount is justified (market benchmarking or company financial constraints). Update your payroll system and loonheffing filings accordingly. If the increase materially affects cash flow, discuss dividend versus salary planning with your advisor.

What changed

The Wet minimumbelasting 2024 (Minimum Tax Act 2024) implements the OECD Pillar Two rules and the EU Minimum Tax Directive. It applies to MNE groups and large domestic groups with consolidated annual revenues of EUR 750 million or more. A Qualified Domestic Minimum Top-Up Tax (QDMTT) ensures the Netherlands collects any top-up tax before other jurisdictions can. The Income Inclusion Rule (IIR) applies to Dutch parent entities with low-taxed subsidiaries abroad. The first fiscal year covered is accounting years starting on or after 1 January 2024.

Who it affects

• Multinational groups with EUR 750m+ consolidated revenue
• Dutch subsidiaries of qualifying MNE groups
• Dutch parent companies with overseas subsidiaries
• Large domestic groups meeting the revenue threshold

What to do

Determine whether your group meets the EUR 750 million revenue threshold and assess effective tax rates per jurisdiction. Engage transfer pricing and international tax advisors to model potential top-up tax exposures. Prepare for new data collection and reporting requirements — the first QDMTT returns will be due in 2026 for 2024 fiscal years. Review whether Safe Harbour provisions (Transitional CbCR Safe Harbour) reduce your compliance burden in the initial years.

What changed

The Dutch KOR (Kleineondernemersregeling) allows businesses with annual turnover below EUR 20,000 to be exempt from BTW (VAT) administration and payment. From 1 January 2025, the EU SME scheme came into force across all EU member states: Dutch businesses can register for the BTW exemption in other EU countries where they make supplies, provided they remain below that country's threshold and the EUR 100,000 EU-wide cap. Conversely, EU businesses from other member states can use the Dutch KOR if they stay within the EUR 20,000 Dutch threshold.

Who it affects

• Small businesses and freelancers under EUR 20,000 annual turnover
• Businesses supplying goods or services across EU borders
• E-commerce sellers reaching customers in multiple EU countries
• Sole traders and ZZP-ers considering the BTW exemption

What to do

If your turnover is below EUR 20,000 annually, register for the KOR via the Belastingdienst to eliminate BTW administration. If you make cross-border EU supplies, assess whether the new EU SME scheme simplifies your VAT obligations in other member states. Note that KOR participants cannot deduct BTW on business purchases, so model the net benefit for your specific cost structure before opting in.