Dutch Tax Outlook 2027: What international enterprises need to know

Corporate income tax rates 2027

The corporate income tax rates and brackets will remain unchanged in 2027 compared to 2026:

Corporate tax rates

New safe harbours under the Minimum Tax Act 2024 (Pillar Two)

The Minimum Tax Act 2024 (Wet minimumbelasting 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. Following the Side-by-Side agreement reached within the OECD Inclusive Framework on 5 January 2026, a separate bill accompanying the Belastingplan 2027 package adds a set of new safe harbours to the Dutch regime:

• a simplified effective tax rate safe harbour, which is made permanent;
• a safe harbour for qualifying equivalent minimum tax regimes, reducing the top-up tax to nil for groups headed in a jurisdiction operating such a regime;
• an ultimate parent entity safe harbour, replacing the temporary UTPR safe harbour under stricter conditions;
• a safe harbour for qualifying fiscal incentives, giving states room to support genuine innovation and sustainability investment without triggering top-up tax.

The temporary CbCR safe harbour is extended by one year. The rules are intended to enter into force on 1 January 2027, with retroactive effect for a number of provisions.

The practical impact is most visible for groups headed in the United States. The Inclusive Framework has established that the US minimum tax system meets the qualifying conditions, which means US-parented groups fall outside IIR and UTPR top-up taxation. Withholding taxes at source are unaffected, and the design is scheduled for a stocktake in 2029.

DAC9: the first exchange round in practice

EU Directive DAC9 (Directive (EU) 2025/872) strengthens the exchange of information on Pillar Two matters among EU tax authorities. Its key feature is the standardised Top-up Tax Information Return, a single consolidated declaration that is automatically shared with the relevant EU Member States. In the Netherlands the directive is implemented through the Wet op de internationale bijstandsverlening bij de heffing van belastingen (WIB) and the Wet minimumbelasting 2024.

The first Top-up Tax Information Return was due on 30 June 2026 for financial years starting in 2024, with subsequent returns due within 15 months of the end of the financial year. Member States exchange the information within three months of the filing deadline, extended for the first round. 2027 is therefore the first year in which multinational groups will see the consequences of the exchange in practice, and in which the quality of the data filed becomes visible to more than one tax authority at a time.

CBAM: the first full compliance cycle

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. It applies to products in the sectors of steel and iron, cement, fertilizers, aluminium, and electricity.

The transition period ended on 31 December 2025. Since 1 January 2026 CBAM goods may only be imported into the EU by an authorised CBAM declarant, and the quarterly reporting obligation has been replaced by an annual CBAM declaration combined with the surrender of CBAM certificates. Following the Omnibus simplification, importers remaining below a de minimis threshold of 50 tonnes of CBAM goods per calendar year fall outside the obligations.

2027 is the first year in which the definitive regime is settled: the CBAM declaration covering the 2026 import year must be filed by 30 September 2027, and the sale of CBAM certificates starts in the course of that year. For importing groups this turns CBAM from a reporting exercise into a cash-flow and pricing item, and makes the availability of verified supplier emissions data a commercial issue rather than an administrative one.

Participation exemption: currency hedging results narrowed

The participation exemption (deelnemingsvrijstelling) covers currency results on instruments used to hedge the currency risk on a qualifying participation, provided the taxpayer has opted for that treatment. The government proposes to narrow this: for financial years beginning on or after 1 January 2027, only the currency result in the narrow sense would remain within the exemption, while the priced-in component of the hedging instrument would be taxable.

Groups that hedge participations in foreign currency — in practice most Dutch holding structures with non-euro subsidiaries — should review existing hedge documentation and the election made before the start of the first affected financial year.

Business merger and demerger facilities eased

Following Supreme Court case law, the presumption of abuse in the business merger and demerger facilities is removed. Where a merger or demerger is not predominantly aimed at avoiding or deferring taxation, the taxpayer no longer has to rebut a statutory presumption to the contrary. This is a welcome simplification for cross-border reorganisations and for pre-transaction restructuring in an M&A context, although the general anti-abuse test itself remains.

Expat regime: from 30% to 27%

The expat regime (art. 31a Wet LB 1964, generally still referred to as the 30% ruling) is reduced as of 1 January 2027. The maximum tax-free allowance falls from 30% to 27% of the gross salary, and the salary norm is increased — indexed from €48,013 in 2026 to approximately €52,500, with a lower norm for employees under 30 holding a recognised master's degree.

Transitional rules apply: employees who already benefited from the regime in December 2023 retain 30% for the remainder of their eligibility period, and employees who used the regime in December 2024 continue under the previous salary norms. Internationally mobile employers should nevertheless expect the net cost of inbound assignments to the Netherlands to rise from 2027 and to re-run their gross-up calculations accordingly.

A new employer contribution: the vrijheidsbijdrage

To finance increased defence spending, the government introduces a "vrijheidsbijdrage" (freedom contribution) from 2027. For employers it takes the form of an increase in the Aof premium, amounting to approximately €1.5 billion in 2027 and €1.7 billion structurally from 2028. Although not a corporate income tax measure, it raises the employer wage cost base in the Netherlands and is relevant for groups benchmarking Dutch employment cost against other European locations.

Real estate transfer tax on residential investment property

The transfer tax rate for residential property that is not the buyer's own main residence is reduced from 8% to 7% as of 2027, following the earlier reduction from 10.4% to 8% in 2026. For foreign investors in Dutch residential real estate this continues a gradual correction of the rate, although the combination with the earnings stripping rules (EBITDA threshold 24.5%) remains the decisive factor in most acquisition models.

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