Netherlands: Insights into upcoming 2025 Tax Plan package

General insights into proposals to be included in upcoming 2025 Tax Plan package

General insights into proposals to be included in upcoming 2025 Tax Plan package

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


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