Netherlands: Q&A document on Minimum Tax Act 2024

The Q&A document provides important clarifications on the application of the minimum tax rules (Pillar Two / global anti-base erosion (GloBE)) in the Netherlands.

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September 8, 2025

The Dutch tax authorities on September 2, 2025, published a question and answer (Q&A) document (Dutch) regarding the Minimum Tax Act 2024.

The Q&A document provides important clarifications on the application of the minimum tax rules (Pillar Two / global anti-base erosion (GloBE)) in the Netherlands and is intended to offer taxpayers practical guidance for implementing this complex legislation. Other relevant sources of interpretation include amongst others the consolidated OECD Commentary, parliamentary documents and tax policy statements.  

Highlights of the document include:

  • Distinction between International Financial Reporting Standards (IFRS) and IFRS-EU
  • Domestic minimum top-up taxes – application of the local accounting standard
  • Treatment of changes to earn-out obligations after acquisition / disposal
  • Adjustments to tax expenses relating to prior years
  • Transitional rule regarding deferred tax assets

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

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