Discounts on employers’ own products to be allocated to the discretionary scope of the Work-Related Costs Scheme
The specific exemption for employers’ own industry-related products under the Work-Related Costs Scheme (WKR) will be abolished. Employers may still offer employees discounts on their own products or services, but these discounts will have to be allocated to the discretionary scope of the WKR.

For 2027, the WKR discretionary scope, meaning the portion of remuneration and benefits that may be provided tax-free, will be 2.16% of the taxable wage bill up to €400,000 and 1.18% of the excess.

For employers that regularly provide their own industry-related products or services to employees, this measure may reduce the discretionary scope available under the WKR.

Increase in the tax-free travel allowance
The government proposes increasing the specific exemption for business travel expenses from €0.23 to €0.25 per kilometre. Employers may reimburse business kilometres tax-free up to this amount.

The increase will apply retroactively from 1 January 2026 and will provide employees with some compensation for rising mobility costs.

More gradual phase-out of the youngtimer scheme
The previously proposed increase in the age threshold for the youngtimer scheme from 15 to 25 years from 1 January 2027 will not proceed. Instead, the government has opted for a gradual increase.

The age threshold will increase to 17 years from 1 January 2027 and to 20 years from 1 January 2028.

Transitional rules will apply to vehicles already made available to employees before 31 December 2025. These vehicles may continue to qualify for the youngtimer scheme in 2026 and 2027.

Introduction of a greentimer scheme
From 2029, a new tax regime for older electric vehicles will be introduced: the greentimer scheme.

Under this scheme, electric vehicles between five and eight years old may qualify for a reduced taxable benefit rate of 14% for up to three years. The scheme will apply from 2029 to 2032, allowing the final group of users to benefit from this temporary incentive until 2035.

The aim is to encourage the use of older electric vehicles and make the second-hand electric vehicle market more attractive.

Penalty tax on fossil-fuel company cars, subject to exceptions
Employers that make a fossil-fuel passenger car available to an employee for private use from 1 January 2027 may be subject to an additional penalty tax of 12% of the vehicle’s catalogue price, including VAT and private motor vehicle and motorcycle tax (BPM).

The Tax Plan contains several exceptions to this additional penalty tax. This penalty tax will not apply to:

• replacement vehicles made available temporarily for a maximum of fourteen days due to damage, maintenance or repairs;
• vehicles made available for no more than seven consecutive days per calendar year;
• driving school vehicles with a manual transmission;
• vehicles already made available to an employee before 1 January 2027. Transitional rules will apply to these vehicles until 1 January 2031.

An anti-cumulation provision will also be introduced. This will prevent employers from being liable for both the penalty tax on fossil-fuel company cars and the final levy on excessive severance payments in respect of the same vehicle.

Tax incentive for employee share options
To make employee participation arrangements more attractive for start-ups and scale-ups, the government proposes a tax incentive for employee share options.

Under the proposal, only 65% of the taxable benefit relating to the increase in value above the market value of the shares will be treated as taxable income from employment. In addition, the taxable moment will shift from the moment the shares become tradable to the moment the shares are actually sold.

The scheme is intended to help start-ups and scale-ups attract and retain talent through employee share participation. The facility will only be available to start-ups and scale-ups holding a formal designation issued by the Netherlands Enterprise Agency (RVO).

Pensionable salary cap to be frozen for six years
For tax-facilitated pension accrual, a maximum pensionable salary of €137,800 applies. The government proposes freezing this cap from 2027 to 2032.

Corporate income tax rates to remain unchanged
No changes are proposed to the corporate income tax (CIT) rates and tax brackets in 2027.

The lower rate of 19% will continue to apply to the first €200,000 of taxable profit in 2027. Taxable profit above €200,000 will remain subject to a corporate income tax rate of 25.8%.

Abolition of the presumption of tax avoidance for mergers and demergers
Subject to certain conditions, a business merger or legal demerger may take place without immediate corporate income tax consequences. In such cases, the tax claim is rolled over to the acquiring entity.

Earlier this year, the Dutch Supreme Court ruled that the presumption of tax avoidance under the demerger facility, which applies when shares are disposed of within three years of the restructuring, is not aligned with the EU Merger Directive.

As a result, the government proposes to abolish this presumption of tax avoidance for both the demerger facility and the business merger facility for the corporate income tax.

For the time being, the comparable presumption under real estate transfer tax legislation will remain in place.

Expansion of the innovation box regime
The innovation box allows qualifying profits derived from self-developed innovations to be taxed at an effective tax rate of 9%. For innovative SME businesses, a simplified fictitious innovation box regime is available. Under this regime, up to 25% of the company’s profits may be treated as qualifying innovation box income, subject to a maximum annual amount.

To improve accessibility for innovative SME businesses, the government proposes to increase the maximum fictitious innovation box benefit from €25,000 in 2026 to € 100,000 per year as of 2027. As a result, innovative entrepreneurs will be able to benefit from the innovation box more easily, without the need for extensive calculations or complex administrative procedures.

Reduction in the transfer tax rate for investment properties
The government proposes reducing the transfer tax rate for residential properties not used as a principal residence from 8% to 7% from 2027. The reduced rate will apply to rental properties, holiday homes and second homes, among others.
The reduced rate may also apply to related assets, such as garages and storage units, acquired together with the property.

For residential properties that will be used by the purchaser as their principal residence, the existing transfer tax rate of 2% will remain applicable.

With this measure, the government aims to encourage investments in residential real estate. As a result, investors and other purchasers of non-owner-occupied properties will benefit from a lower transfer tax burden upon acquisition.

No overlap between the excessive borrowing rules and inherited substantial interests
The government proposes eliminating the interaction between the excessive borrowing rules and the inheritance tax facility for substantial interests.

Under the excessive borrowing rules, a substantial-interest shareholder may be subject to Box 2 taxation if debts owed to their own company exceed the amount of €500,000.

Following a death, a separate facility currently allows certain dividend distributions to be made within 24 months without triggering immediate taxation, provided the applicable conditions are met.

According to the government, this facility was never intended to enable the avoidance of Box 2 taxation on excessive debts owed to a private limited company (BV). The government therefore proposes excluding this interaction.

The government also indicates that this measure will help prevent potential double taxation in the future.

For director-major shareholders with significant debts to their own company, this proposal may have an important impact on estate planning.

Temporary reduction in motor vehicle tax for business vans and trucks
To provide support for businesses facing increased transportation costs, the government proposes a temporary reduction of motor vehicle tax (MRB).

Motor vehicle tax for business vans will be reduced by 50% for six months. A zero rate will apply to trucks during the same period.

The temporary reduction will apply from 1 July 2026 until 1 January 2027.

Temporary reduction of the truck levy
Since 1 July 2026, operators of heavy-duty trucks have been subject to a truck levy for using certain roads. The amount payable depends on the number of kilometres driven and the vehicle’s characteristics.

In response to the significant increase in fuel prices resulting from geopolitical developments in the Middle East, the government proposes temporarily reducing the levy by 22.3%. The reduction will apply from 1 September 2026. The regular truck levy rates will apply again from 1 January 2027.