Dutch Tax Outlook 2026: What international enterprises need to know

2026 Tax Plan for International Entrepreneurs

As part of the 2025 budget day (Prinsjesdag) announcements, the Dutch government outlined several key updates to Dutch taxation for 2026. This section highlights the most relevant developments for internationally active businesses, financial institutions, and multinational groups.

Corporate income tax rates 2026

The corporate income tax rates and brackets will remain unchanged in 2026 compared to 2025:

Corporate tax rates

Adjustment of the Carbon Border Adjustment Mechanism (CBAM)

CBAM is a measure introduced by the European Union to account for CO₂ emissions released during the production of certain goods outside the EU. Its aim is to prevent companies outside the EU from gaining a competitive advantage due to less stringent climate regulations.

Initially, CBAM applies only to products in the sectors of steel/iron, cement, fertilizers, aluminium, and electricity. A transition period is in place until 2026, during which importers are not yet required to pay levies. However, they must submit quarterly reports detailing the volume of CBAM-covered goods imported and the associated emissions. 

From 2026, CBAM will be fully implemented, with additional legal provisions to be introduced.

Adjustment of the minimum capital rule for banks and insurance companies

The government proposes a technical refinement to the minimum capital rule in corporate taxation, originally introduced in 2020 to limit interest deductions for banks and insurance companies. A 2024 amendment allowed interest on group loans to be deductible under certain conditions to address liquidity management imbalances. However, the scope of the exception was too broad, inadvertently including loans linked to borrowings from individuals (e.g., deposits). To correct this, loans directly tied to borrowings from individuals will no longer be exempt from the rule for financial years starting on or after 1 January 2026. Consequently, interest on these loans will again fall under the minimum capital restriction.

Adjustments to the Minimum Tax Act 2024 (Pillar Two)

The Minimum Tax Act 2024, also known as Pillar Two, introduced a minimum effective tax rate of 15% per jurisdiction for international enterprises with annual revenues exceeding €750 million. The law is now being supplemented with elements from the administrative guidelines. Additionally, several technical changes are being implemented to further refine the regulation.

Implementation of EU Directive DAC9

The EU Directive DAC9 strengthens the exchange of information on Pillar Two matters among EU tax authorities. A key feature is the introduction of a standardized ‘Top-up Tax Information Return’ form. Multinational groups will be required to submit such a single consolidated declaration, which is automatically shared with the relevant EU Member States.

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For more information about international tax or tailored advice on how these measures may impact your organization, please contact our tax adviser. We're happy support you with further clarification or strategic guidance.