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Netherlands: Consultation on changes to participation exemption and currency gains and losses on hedging instruments

Consultation commenced on March 2, 2026

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March 5, 2026

A draft bill proposing amendments to the participation exemption with respect to the tax treatment of currency gains and losses on hedging instruments—which were announced in the 2026 Budget Memorandum—was published for consultation on March 2, 2026.

The draft bill proposes:

  • For financial years commencing on or after January 1, 2027, only have the participation exemption apply to unpriced currency results on a currency hedging instrument that serve to hedge any currency risk run with a participation
  • Removal of several implementation problems with the participation exemption and currency hedging instruments

Read a March 2026 report prepared by the KPMG member firm in the Netherlands

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