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An expert in corporate and international corporate law. He has many years of experience in establishing and reorganizing companies, supporting M&A transactions, as well as providing legal support for opening and running a business in the EU, Asia, and North America.
Tax structuring in the Netherlands
In accordance with the principle of lex scripta and in the context of the tax sovereignty of the Kingdom of the Netherlands, the adopted Belastingplan 2025 (Tax Plan 2025) establishes fundamental changes in the taxation system of legal entities and individuals. The Netherlands, as an EU Member State operating under the Rome I Regulation and adhering to the principles of the OECD Model Tax Convention, continues to harmonize national legislation with international standards. Below, we will discuss the key modifications to tax legislation that have entered into force since 2025 and establish their legal consequences for business entities.
Corporate income tax (Vennootschapsbelasting, Vpb)
- The standard rate from 2025 remains at 19% for the first €200,000 of profit. That is, if a company with a revenue of €300,000 pays 19% on €200,000 and 25% on the remaining €100,000.
- Full Participation Exemption – income from dividends, sale of shares and royalties is not taxed if the company owns 5%+ shares of a subsidiary.
From 2025, updated criteria for determining the residency and tax status of legal entities came into force, namely:
- Actual management: Location of the management bodies (e.g. the board of directors meeting in the Netherlands).
- Economic presence: Presence of an office, staff, assets in the country. This means that companies that do not meet the residency criteria may lose access to double taxation agreements.
- The need to review the business structure (for example, for holding companies).
Dividend tax (Dividendbelasting)
- Basic rate – still 15% for residents and non-residents.
- Exemption for participants: Full exemption – if dividends are received by a company that owns 5%+ of the shares of the receiving party. Partial exemption – for non-residents under the terms of double taxation agreements.
- Implementation of the DAC9 directive: From December 31, 2025, multinational companies (with revenue exceeding €750 million) will be required to submit additional information on business structure, taxes and transfer pricing. The requirements are as follows: CbCR+ (Country-by-Country Reporting Plus) file in digital format; Detailed description of operations related to IP, financial transactions. Fines for non-compliance are up to €1 million or 4% of global revenue.
Personal Income Tax (Inkomstenbelasting)
- Increase in Tax-Free Allowance: From 2025–2026, it is set at 30% (previously 27.65%). For example, an employee with a salary of €50,000 will receive an allowance of €15,000. Salary cap – details of the maximum amount will be published in an amendment to the law.
- Income tax cut: In 2025, a tax cut is expected for the middle class due to an increase in the tax-free minimum. For small businesses, this means a reduction in wage costs, as well as an increase in the purchasing power of the population, which stimulates consumption.
Savings tax (Box 3)
From 2025, the rules for taxing savings and investments (Box 3) have been revised. Main changes:
- Increase in the tax-free threshold to €57,000 (for couples – €114,000).
- New formula for calculating tax on income from securities.
- Support for entrepreneurs.
- Benefits for startups: Increase in the investment benefit (InnoStep) to 50% of R&D costs (up to €25,000); Simplification of the procedure for obtaining grants through the RVO Netherlands portal.
- Changes in benefits for entrepreneurs: Revision of the conditions for obtaining zelfstandigenaftrek (benefits for the self-employed).
- Digitalization of tax procedures: Launch of the eTax Portal 2.0 for filing declarations and paying taxes; Automatic synchronization of data with banks and social funds.
Therefore, the tax changes introduced in the Netherlands from 2025 require a comprehensive review of business strategies. According to the Belastingplan 2025, the key priorities for enterprises are:
- Verification of residency status – checking compliance with the criteria of actual management and economic substance, which is especially critical for holding structures. The abolition of partially non-resident tax status requires a review of the jurisdiction of assets and income.
- Adaptation to DAC9 – implementation of the Country-by-Country Reporting Plus (CbCR+) system, which provides for a detailed audit of the business structure, identification of controlled transactions and preparation of digital data for automatic exchange of information between EU tax authorities.
- Optimization of the tax burden – use of benefits for IT companies (for example, exemption from IIN in Lithuania) and restructuring of savings in Box 3 (Netherlands), where the tax-free threshold has been increased to €57,000 from 2025.
Tax optimization
Tax optimization under Pillar Two (global minimum corporate tax) requires:
- Analysis of transfer pricing taking into account the new DAC9 rules, which simplify reporting for large groups, but strengthen compliance control.
- Restructuring of holdings to avoid double taxation, especially in the context of the abolition of benefits for non-residents.
- Investments in R&D – use of InnoStep (Netherlands) or summer benefits for IT specialists, which reduce the effective tax rate.
What services does Prikhodko & Partners Law Firm offer?
Our company Prikhodko & Partners offers comprehensive solutions for effective business structuring in the Netherlands:
- Optimization of tax liabilities – use of benefits for IT companies, investments in R&D (InnoStep), as well as structures that meet the Full Participation Exemption criteria.
- DAC9 compliance – transfer pricing audit, preparation of CbCR+ reporting and integration with automatic data exchange systems.
- Risk minimization – advice on avoiding double taxation, analysis of changes in Box 3 and verification of compliance with new residency criteria.
We specialize in international tax planning, have experience with Dutch law, and are up-to-date on the Belastingplan 2025 update. We will help your business not only adapt to the new requirements, but also take advantage of the Dutch tax system for growth and innovation.
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