Netherlands: Interest rate on corporate income tax due found contrary to principle of proportionality (Supreme Court Advocate General opinion)

8% interest rate must be reduced

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October 2, 2025

The Supreme Court on September 26, 2025, published the nonbinding opinion of its Advocate General (AG) in case number 24/04619, regarding whether the 8% interest rate on tax due for corporate income tax applied in 2022 and 2023 is contrary to the principle of proportionality.

The District Court of Noord-Nederland in November 2024 held that the 8% interest rate was contrary to the principle of proportionality, and that the interest on tax due for those years must be calculated at 4%. The Deputy Minister of Finance appealed to the Supreme Court, and the AG concluded, on various grounds, that the rate for interest on tax due of 8% cannot be maintained and must be reduced.

The AG specifically found that the following interest rates would be appropriate for the years below:

  • 2022: 2%
  • 2023: 6%
  • 2024: 7%
  • 2025: 6%

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

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