Netherlands: Clarifications on corporate income tax treatment of cooperative exit payments and downward interest adjustments
The Dutch Tax Administration issued guidance on exit payments received by cooperatives and downward interest adjustments on non-business-related loans.
July 28, 2026
The Dutch Tax Administration published Knowledge Group clarifications on the corporate income tax treatment of exit payments received by a cooperative from departing members, and downward interest adjustments on a non-business-related loan under the arm’s length principle.
- Cooperative exit payments (published on June 12, 2026): The clarification states that such exit payments do not qualify as capital contributions and therefore increase the cooperative’s taxable profit for corporate income tax purposes.
- Downward interest adjustments (published on June 17, 2026): The clarification confirms that reducing the agreed interest rate from 5% to 3% constitutes a downward profit adjustment, and that Article 8bb of the Corporate Income Tax Act 1969 applies to deny the adjustment when no corresponding upward adjustment is taxed at the borrower’s level.
For more information, contact a KPMG tax professional in the Netherlands:
Paul te Boekhorst | teboekhorst.paul@kpmg.com