Netherlands

Last modified: 25/03/2025 12:46

Corporate taxation

	Rate
Corporate income tax rate	19/25.8
Branch tax rate	19/25.8
Capital gains tax rate	19/25.8

1. The first € 200,000 profit is taxed at 19% and the profit exceding this treshold at 25,8%. Further to this general rate, there is a special regime (innovation box) for certain research and development activities (tax rate under the innovation box is 9%)

Residence: A company is resident in the Netherlands if it is incorporated there or where the company has its place of central management and control there.

Basis: A resident company is subject to corporation tax (corporate income tax) on its worldwide profits and gains; profits and gains of foreign permanent establishments are exempt. Non-resident companies are taxable on their Netherlands-source income and gains.

Taxable income: Broadly based on adjusted GAAP profits. Foreign-source income is included in taxable income, but relief is granted for dividend income and capital gains from qualifying participations and foreign permanent establishments. Business expenses are deductible.

Significant local taxes on income: None

Alternative minimum tax: N/A

Taxation of dividends: Dividend receivables are considered general taxable income. However the participation exemption applies to most dividends receivable where there is a participation of 5% or more. An exemption also applies to most dividends payable under the participation exemption. Dividends paid to shareholders based in jurisdictions included in the list of non-cooperative jurisdictions of the European Union (EU) or jurisdictions with a tax rate lower than 9% will be subject to the withholding tax.

Capital gains: Capital gains form part of a resident company’s taxable profits. Gains from qualifying participations are tax-exempt.

Losses: Losses may be carried back one year and carried forward unlimitedly. If the profits in a year exceeds € 1.000.000, the losses higher than 1.000.000 can only be deducted for 50% of the taxable profit.

Foreign tax relief: The Netherlands has concluded tax treaties with roughly 100 countries. In general, worldwide income is taxable and income from foreign PEs and foreign real estate is exempt. Foreign-source income is included in taxable income, but relief is granted for dividend income from qualifying participations.

Participation exemption: Yes (on qualifying 5% holdings or more).

Holding-company regime: There is no general holding company regime, there are however CFC regulations.

Tax-based incentives: • Clarity and certainty in advance on tax consequences. Rulings may be obtained from the tax authorities • There is an optional tonnage tax for shipping companies. • Innovation box with a 9% effective tax rate.

Group relief/fiscal unity: Consolidated filing. No consolidated filing outside the fiscal unity regime. Assets may be transferred intra-group at no gain/no loss. Losses and gains can be offset within the fiscal unity.

Small company/alternative tax regimes: None.

Corporate taxation: compliance

Tax year: Accounting period (cannot exceed 12 months except in the year of incorporation).

Consolidated returns: Yes, if the fiscal unity regime is applied.

Filing and payment: Self-assessment. Returns must be filed electronically and tax must be paid within 12 months of the accounting-period end. Postponement is available in principle up to 11 months after the initial deadline i.e. 1 May in the following financial year..

Penalties: Failure to file return: fixed penalties. Tax-geared penalties for carelessly or deliberately incorrect returns.

Rulings: Rulings may be obtained from a special team of the tax authorities on various tax matters. They issue Advance Pricing Agreements and Advanced Tax Rulings. The rulings are published.

Taxation of individuals

	Rate
Bands	Personal Income Tax
Till € 38,098	9.32
From € 38,098 up to € 75,518	36.97
From € 75,518	49.50

1. In the first bracket of box 1, national insurance tax is levied at a rate of 27.65%.
2. Box 2 income in 2024 has two brackets:
   • up to € 67,000 a tax rate of 24.5%,
   • from € 67,000 a tax rate of 33%. 
3. Box 3 income is taxed at a flat rate of 36%.

Residence: An individual’s residence position is determined based on all (relevant) facts and circumstances, important facts are: Where a permanent home is maintained. Where employment duties are performed. Where the individual’s family resides. Where the individual is registered with the local authorities. Where bank accounts and other assets are maintained.

Basis: Taxpayers are generally taxed on an individual basis. The tax base is the worldwide income. There is aggregation of certain types of incomes of spouses, civil partners and fiscal partners.

Taxable income: Income is broadly classed as (1) income from work; (2) income from shareholding (5% or more); and (3) capital. Separate calculation and deduction rules are applied to each class before taxable income is aggregated and taxed on a current-year basis.

Capital gains: No capital gains tax.

Deductions and allowances: Yes. Deduction is possible for alimony paid, expenses for specific care costs, costs for temporary stay at home of severely disabled persons, donations to recognised institutions, annuity premiums and paid interest on certain mortgages. Subject to change.

Foreign tax relief: Yes. Relief is by the credit method but may not exceed the Netherlands tax payable on the foreign income.

Taxation of individuals: compliance

Tax year: Calendar year

Filing and payment: Self-assessment. Spouses, civil and fiscal partners file jointly. Tax on employment income is withheld by the employer.

Penalties: Failure to file return: fixed penalties. Tax-geared penalties for carelessly or deliberately incorrect returns. The risk of high tax interest on tax returns after the 1st of may.

Rulings: Yes

Withholding taxes

Type of Payment	Resident recipients		Non-residents recipients
	Company	Individual	Company and Individual , Non-treaty situations
	Rate (%)	Rate (%)	Rate (%)
Dividend	0/15	15	15
Interest	0/25.8	0	0/25.8
Royalties	0/25.8	0	0/25.8

1. xxxxxxxx
2. xxxxxxxx

Branch remittance tax: None

Anti-avoidance legislation

Transfer pricing: Follows OECD principles.

Interest restriction: Net financing costs must not exceed 20% of EBITDA on company or group-wide basis. Excess may be carried forward (indefinitely) as may unused interest capacity. Exemption for first 1 million EUR.

Controlled foreign companies: Yes. Broadly where a Netherlands company and its associates (i.e. at least 25% interest) have a direct or indirect interest in at least 50% of a non-resident company controlled by Netherlands residents. Rules apply per income stream and only where income passes through a “gateway”, e.g. low taxation, insufficient substance.

Hybrid mismatches: Deductions are denied or income receipts brought into Netherlands tax to counteract mismatches arising under 8 different scenarios and in respect of “imported” mismatches.

Disclosure requirements: DAC6/MDR in place on aggressive cross-border planning and Country-by-Country reporting obligations with international groups with a turnover above € 750 million euros

Exit taxes: For companies ceasing to be resident, deemed disposal and reacquisition at market value on most chargeable assets. For individuals ceasing to be resident, deemed disposal and reacquisition at market value of major shareholdings (box 2).

General anti-avoidance rule: A general anti-abuse rule applies across most important taxes. Allows tax authorities to counteract tax advantages arising from abusive arrangements. There are many targeted anti-avoidance rules for specific situations.

Digital services tax and Other significant anti-avoidance legislation: None

Value-added tax/Goods and services tax

Type of tax: Value-added tax (VAT), VAT is collected on most supplies of goods and services. The supplier has under conditions the right to deduct VAT on purchases (input VAT)

Standard rate: 21%

Reduced rates: 9%

Registration: Anyone – resident or not – who is supplying goods or services in return for payment in the Netherlands should in principle register for VAT. However, exceptions possible. For example foreign companies sometimes do not have to register due to local VAT reverse-charge rules.

Filing and payment: VAT filing on a quarterly basis. VAT filing and payment within one month of the end of the quarter. For foreign companies – not seated in the Netherlands nor having a fixed establishment in the Netherlands, the filing and payment must be done within two months of the end of the quarter. For intra-EU supplies an EU sales list must be filed on a monthly or quarterly basis, depending on the volume of goods sold to taxable persons in other EU Member States

Social security contributions

Employee insurance contributions and national insurance tax are levied on residents and non-residents under a number of different regulations. 

National insurance tax

Under the national insurance tax regulations, contributions are levied on income up to a maximum of EUR 38,098 with a maximum contribution of EUR 10,534. From these contributions several levy rebates may be deducted. National insurance contributions are paid by the employee and are not deductible. National insurance contributions and income taxes are included as a single tax in the first income tax bracket. National insurance comprises the General Old Age Pensions Act (AOW), Surviving Dependents Act (ANW) and Long-Term Care Act (Wlz).

Employee insurance contribution

Under the employee insurance regulations, contributions are to be paid on income up to a maximum of EUR 71,628. The contribution rate depelds on the employer’s industry. There is also a difference in the unemploymend benifit (WW) contributions for employees with a fixed-term contract and employees with a flexible contract. The employee insurances are the Unemployment Insurance Act (WW), the Disability Insurance Act (WAO), the Work and Income according to Labour Capacity Act (WIA) and the Sickness Benefits Act (ZW)

Dutch Health Insurance Act

It is obligatory for all residents of the Netherlands and all employees who are subject to Netherlands wage tax to be covered under the Netherlands Health Insurance Act and to have a statutory health insurance policy. For employees the contribution will consist of:

• a nominal contribution of approximately EUR 1,768 (including EUR 385 own-risk), to be paid to the health insurance company, and
• an income-related contribution (6.57% on income up to a maximum of EUR 71,628, with a maximum of EUR 4,705), to be paid to the Netherlands tax authorities by the employer.

Self-employed

The self-umployed pay only the national insurance tax, which comprises the General Old Age Pensions Act (AOW), Surviving Dependents Act (ANW), Long-Term Care Act (Wlz), and Child Support (Kinderbijslag).

Other taxes

Capital duty: None.

Immovable property taxes: The municipality will levy a property tax. This is a fixed percentage of the official listed value. This rate ranges from 0.0431% (municipality Amsterdam) to 0.1781% (municipality Nijmegen)

Transfer tax: The transfer of immovable property or certain rights thereto (e.g. buildings, houses, shares in real-estate companies) is subject to transfer tax, payable by the new owner. A home in which the buyer is going to live and when the buyer is not eligible for the starter’s exemption, the transfer tax is 2%. Other real estate, such as vacation homes and commercial properties, is subject to an 10.4% rate.

Stamp duty: None

Net wealth/worth tax: The Netherlands taxes net worth on the basis of fictitious rates of return that are close to the actual rates of return. There is no taxation for capital gains or actual rental income recieved (limitations present). The assets are categorised under one of three categories which will be valued on 1 Januari will each be deemed to generate an annual fixed return on investment: 1 Bank deposits (savings): 1.03% 2. Investments and other assets 6.04% 3. Debts 2.47% This fictitious yield is taxed at a flat rate of 36%. For a net worth up to €57,000 (€ 114,000 with a fiscal partner), there is a tax-free allowance. For a net worth from €57,000, the taxpayer is assumed to generate the fixed returns mentioned above.

Inheritance/gift taxes: Yes. The Netherlands levies gift and inheritance tax on assets gifted by or inherited from individual residents of the Netherlands. The tax is levied on the recipient. The tax rate depends on the value of the gifted taxes and the relation to the donor or deceased (10% to 40%). Transfers up to a certain value are exempt, depending on the relation of the recipient to the donor or deceased.

Other: Insurance premium tax. Tax on games of chance. Tax on passenger cars and motor vehicle tax etc. The ‘Minimum Tax Act 2024 (Pillar Two)’, is adopted by the Netherlands as of 1 januari 2024. This establishes a minimum tax system with a minimum effective tax rate of 15% at the jurisdictional level. Companies with a consolidated turnover of at least 750 million euros will fall within the scope of Pillar Two.

Tax treaties

The Netherlands has concluded over 100 full double taxation treaties on income and capital gains and has a small number of tax information-exchange agreements. It has a handfull estate-tax treaties. It is also a signatory to the OECD Multilateral Instrument.