Dutch Tax Plan 2027: key takeaways for international businesses

The proposals cover a broad range of areas, from corporate taxation and employment to international tax rules and investment incentives. While the legislative process is still ongoing, now is the time to assess which developments could affect your organisation.

We highlight some of the key developments below.

The Dutch Tax Plan 2027 contains a broad package of proposed tax measures. Most are intended to enter into force on 1 January 2027, although some measures have different effective dates. The proposals still require approval by both the House of Representatives and the Senate and may therefore change during the legislative process.

For international businesses, the relevance of these measures will depend on their activities, structure, employees and investments in the Netherlands.

Several proposals directly affect companies operating in the Netherlands.

One example is the innovation box. Under the proposed changes, the maximum amount that can be applied under the fixed-sum calculation would increase from €25,000 to €100,000 per taxpayer per year. This could make the simplified method more attractive, particularly for smaller businesses with qualifying innovation income.

There are also proposed changes concerning foreign exchange results related to qualifying participations and changes to the rules applying to certain restructurings.

For businesses operating internationally, these developments underline the importance of reviewing the tax implications of both existing structures and future transactions.

Employers should also prepare for several changes.

The maximum tax-exempt travel allowance has been increased from €0.23 to €0.25 per kilometre, with retroactive effect from 1 January 2026. The discretionary margin under the work-related expenses scheme is also proposed to increase from 2% to 2.16% over the first €400,000 of the wage sum.

Another relevant development for internationally operating employers is the scaling back of the 30% ruling. From 2027, the facility is set to become a 27% facility for certain employees, while transitional rules apply depending on when an employee entered the scheme.

For international businesses employing people in the Netherlands, it is therefore important to assess how these changes may affect employment costs and existing arrangements.

The package also contains measures specifically relevant to cross-border situations.

For example, changes are proposed for the acquisition price used for Dutch Box 2 purposes when a foreign company transfers its effective management to the Netherlands. Under the proposal, the economic value at the time of transfer would become the starting point, so that only subsequent changes in value are subject to Dutch taxation in the situation described in the proposal.

The proposals also introduce new safe harbour rules under the Dutch Minimum Taxation Act. These relate to the global minimum tax framework applicable to large multinational groups.

These developments can be particularly relevant when establishing, restructuring or expanding activities in the Netherlands.

Not every proposal will affect every organisation. The impact depends on factors such as your Dutch activities, international group structure, employees and planned investments or transactions.

The first step is therefore not simply to identify what is changing, but to determine which changes are relevant to your organisation and whether action is required before or during 2027.

Our specialists can help you assess the potential impact of the Dutch Tax Plan 2027 on your organisation.

Want to explore all proposed measures?

Our Budget Day Special – Tax Plan 2027 provides a comprehensive overview of the proposals, including measures for companies, employers, VAT and excise duties, immovable property, mobility, individuals, energy and the environment, and international matters.