The Deputy Minister of Finance on 16 April 2024 sent a letter and tax policy and implementation agenda to the lower house of Parliament providing general insights into proposals to be included in the upcoming 2025 Tax Plan package:
Corporate income tax
- Overlap loss set-off and exemption for debt relief income tax
- Subject-to-tax tests in the Corporate Income Tax Act 1969
- Implementation of the general anti-abuse rule (GAAR) appearing in the ATAD1 directive
- Earnings stripping measure (generic interest deduction limitation)
- No changes to Section 8c CITA 1969
Withholding tax and dividend tax
- New group concept for the Withholding Tax Act 2021
- Withholding exemption
Individual (personal) income tax
- Reduction of threshold for top rate
- Small and medium enterprise (SME) profit exemption to be reduced to 12.03%
Value added tax (VAT)
- Currently VAT regulations do not offer the option of multi-year revision of the VAT deducted on services to immovable property
Climate measures
- Generic increase in energy tax rate for bulk users
- Tightening of CO2 tax on industrial emissions
Status of share redemption, 30% ruling and Personal Income Tax Act 2001 (PITA) rates
- 30% ruling
- Share redemption tax relief, PITA rates and bank tax
Read an April 2024 report prepared by the KPMG member firm in the Netherlands