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Netherlands: Amendments to Pillar Two rules; planned implementation of Pillar Two side-by-side package

Including aligning tax law for BES Caribbean islands with Pillar Two rules

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February 3, 2026

The State Secretary for Finance on December 23, 2025, published the End-of-year Decree 2025, which includes amendments to the implementing decree for the Minimum Tax Act 2024 to align with recent OECD/EU Pillar Two guidance.

In addition, legislative updates published on December 23, 2025, aligned the tax law for the BES Caribbean islands with the Second Amendment to the Minimum Tax Act 2024, the EU DAC9 data exchange implementation law, and the End-of-Year Decree 2025. The updates are effective for fiscal years beginning December 31, 2023.

Finally, the State Secretary for Finance on January 5, 2026, informed Parliament that it plans to submit a legislative proposal implementing the Pillar Two side-by-side package by summer 2026, following stakeholder consultation.


For more information, contact a KPMG tax professional in the Netherlands:

Paul Te Boekhorst | teboekhorst.paul@kpmg.com

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