Netherlands: Class action against interest on tax due charged for corporate income tax

The proceedings pending before the Supreme Court concern interest on tax due charged for the period January 1, 2022 through December 31, 2023.

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February 18, 2025

The Deputy Minister of Finance on February 7, 2025, decided to designate as a class action four categories of notices of objection against interest on tax due that had been charged.

The class action relates to the high interest on tax due rate applying:

  • As of October 1, 2020, for corporate income tax and withholding tax
  • As of January 1, 2022, for the solidarity contribution
  • As of January 1, 2024, for the minimum tax
  • As of January 1, 2025, on the share in the profit under the Mining Act

To participate in the class action, taxpayers must submit notice of objection against the interest on tax due charged on tax returns and timely request a review of the interest on tax due charged on provisional assessments.

Recently, the Dutch tax authorities have received approximately 6,000 notices of objection against interest on tax due charged for corporate income tax purposes in response to the judgment by the Noord-Nederland District Court, in which this interest on tax due was reduced from 8% to 4%.

The Deputy Minister of Finance is appealing this judgment before the Dutch Supreme Court. The cassation proceedings before the Supreme Court are still ongoing.

Read a February 2025 report prepared by the KPMG member firm in the Netherlands

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