Netherlands: DAC8 enacted; qualification as joint venture under Pillar Two rules; other tax developments
Other tax developments include temporary reductions in motor vehicle taxes for commercial transport.
may 26, 2026
Legislation implementing EU Directive (EU) 2023/2226 to introduce reporting and automatic exchange of information for cryptoasset service providers was enacted on April 1, 2026.
Other recent tax developments in the Netherlands include:
- The Dutch Tax and Customs Administration on April 9, 2026, published a position clarifying that an entity qualifies as a joint venture under section 1.2 of the Minimum Tax Act 2024 only if it is accounted for using the equity method and if the ultimate parent holds, directly or indirectly, at least a 50% interest (with qualification arising from the moment that threshold is met).
- The Dutch Tax and Customs Administration on April 8, 2026, published a position confirming that a Spanish Agrupación de Interés Económico (AIE) was, for Dutch tax purposes, comparable to a Dutch maatschap or general partnership, based on the AIE’s nature as a contractual cooperation vehicle, the direct attribution of profits to participants, and the participants’ joint and several liability, and was thus fiscally transparent.
- The Ministry of Finance on April 9, 2026, issued a notice providing that under the hardship clause of section 63 of the Dutch General Tax Act, losses attributable to a dissolved fiscal unity (as a result of liquidation of the parent company) may be carried forward to the subsidiary when the losses economically arose and the business is continued on a tax‑neutral basis.
- The government on April 20, 2026, announced a comprehensive package of measures to mitigate the economic effect of escalating instability in the Middle East on households and businesses, including increasing the tax‑free travel allowance and temporary reductions in motor vehicle taxes for commercial transport.
- The government on April 20, 2026, published Act No. Stb. 2026, 93, amending provisions relating to excise duties on energy and related products by updating statutory rules, definitions, and administrative arrangements.
For more information, contact a KPMG tax professional in the Netherlands:
P.J. te Boekhorst | teboekhorst.paul@kpmg.com