Dutch tax changes 2027: what foreign companies need to know

The Dutch tax changes 2027 were presented on Budget Day, 15 September 2026, in the Tax Plan 2027 package. For most foreign companies with a Dutch BV or branch, the headline is stability: corporate income tax rates do not change. The real changes are in incentives for innovation and energy investments, in the Pillar Two minimum tax for large groups, and in a few rules that were already adopted earlier, such as the reduced expat scheme.

Below we set out what was proposed, what is already law, what it means for a foreign company operating in the Netherlands, and how to prepare your 2027 budget and forecast.

Overview of the Dutch Tax Plan 2027

The Dutch tax changes 2027 were presented on 15 September 2026. Corporate tax rates stay the same; the changes are in incentives, Pillar Two and some measures that were adopted earlier.

The Tax Plan 2027 is a package of bills presented on Prinsjesdag (Budget Day). The House of Representatives (Tweede Kamer) debates the package this autumn and the Senate (Eerste Kamer) votes in December 2026. Until then, everything in it is a proposal and can still change through amendments.

That distinction matters for planning. Some measures that take effect in 2027 were already adopted in earlier tax plans and are certain. Others are new proposals. This table separates the two for the measures most relevant to companies.

The government’s own summary of the package is on the Rijksoverheid Tax Plan 2027 page (in Dutch).

Corporate income tax rates in the Netherlands for 2027

The Dutch tax changes 2027 leave corporate income tax unchanged: 19% on the first €200,000 of profit and 25.8% above. A Dutch subsidiary or a permanent establishment makes a foreign company taxable.

Dutch corporate income tax (vennootschapsbelasting) stays at 19% on the first €200,000 of taxable profit and 25.8% on profit above that. The bracket is not indexed for inflation, so in real terms more profit falls into the top rate each year.

A foreign company is subject to Dutch corporate income tax in two main situations:

• Dutch subsidiary: a BV or NV incorporated in the Netherlands is a resident taxpayer and is taxed on its worldwide profit.
• Permanent establishment: a foreign company with a fixed place of business or a dependent agent in the Netherlands is a non-resident taxpayer and is taxed on the profit attributable to that Dutch presence.

Mere sales into the Netherlands, without a Dutch entity or permanent establishment, usually do not create a corporate income tax liability, although they can create VAT obligations. For the full framework, see our guide to understanding Dutch corporate tax.

New tax incentives for innovation and sustainable investments

The SME innovation box forfait rises from €25,000 to €100,000 and the Energy Investment Allowance from 40% to 45.5%, both proposed from 1 January 2027.

The two most tangible changes for operating companies are a larger innovation box for smaller companies and a richer energy investment deduction.

SME innovation box forfait: from €25,000 to €100,000

The innovation box taxes qualifying innovation profit at an effective rate of 9% instead of 25.8%. Smaller companies with a WBSO R&D declaration can use a flat-rate forfait: they may treat 25% of their profit as innovation income without a detailed allocation. The proposal raises the maximum from €25,000 to €100,000 per year.

A simplified example: a Dutch BV with €400,000 profit and WBSO-qualifying development work can put 25% of its profit, €100,000, in the box. Taxed at 9% instead of 25.8%, that saves €16,800 a year, compared with €4,200 under the current €25,000 cap.

Energy Investment Allowance: from 40% to 45.5%

The Energy Investment Allowance (EIA) gives an extra deduction on top of normal depreciation for qualifying energy-saving assets on the RVO Energy List. The proposal raises the deduction from 40% to 45.5%. On a €100,000 investment the extra deduction rises from €40,000 to €45,500, which at 25.8% means a tax saving of €11,739 instead of €10,320. The total EIA budget does not increase, so applications may run out faster.

Tax implications for foreign companies operating in the Netherlands

For foreign companies the Dutch tax changes 2027 leave the framework intact: a subsidiary and a permanent establishment are taxed differently, and the existing withholding tax rules on cross-border payments remain.

For foreign companies, the Dutch tax changes 2027 mostly confirm the existing framework. The choice between a Dutch subsidiary and a permanent establishment still drives your tax position: a BV files its own corporate income tax return and annual accounts, while a branch is taxed on attributable profit and files under the foreign company’s name. Our article on choosing a branch or subsidiary in the Netherlands compares both.

The rules on cross-border payments also stay in place:

• Dividend withholding tax of 15% on dividends from a Dutch company, often reduced or exempt under a tax treaty or the EU Parent-Subsidiary Directive.
• Conditional withholding tax at the top corporate rate (25.8%) on interest, royalties and dividends paid to related entities in low-tax jurisdictions or EU-listed non-cooperative jurisdictions, and in abusive structures.
• Property transfer tax: foreign investors buying Dutch homes to let benefit from the proposed cut from 8% to 7%. Commercial property stays at the standard rate of 10.4%.

If you employ expats, the move from 30% to 27% under the expat scheme also affects your employment costs. We explain the transitional rules in our article on the 30% ruling in 2027.

What changes for directors, shareholders and employees?

For individuals, the Dutch tax changes 2027 bring a proposed box 2 top rate of 29.2% for 2027 to 2030, a lower excessive borrowing limit and a higher threshold for the top box 1 rate.

The Tax Plan 2027 also changes personal income tax, which matters if your Dutch company has a director-major shareholder (DGA) or Dutch employees.

• Box 2: on 29 September 2026 the government announced a temporary cut of the top box 2 rate on dividends from 31% to 29.2% for 2027 to 2030. The first bracket stays at 24.5%. The cabinet is still seeking parliamentary support.
• Excessive borrowing: the limit for tax-free debt to your own company drops from €500,000 to €420,000 in 2027 and then by €80,000 a year to €100,000 in 2031, under the same announcement. Mortgage loans for your own home stay exempt.
• Box 1: the top rate of 49.50% starts at €80,578 instead of €78,426, and the second bracket rises to 38.16%.
• Box 3: a capital gains tax on financial instruments is planned from 2028; that bill is before the Senate.

For a DGA, the lower box 2 rate makes it worth reviewing the timing of dividends between 2027 and 2030 together with your company’s cash position.

International tax rules and multinational companies

Groups with at least €750 million revenue get new Pillar Two safe harbours from the OECD Side-by-Side package, some with retroactive effect.

The Pillar Two minimum tax (Wet minimumbelasting 2024) applies to groups with consolidated revenue of at least €750 million in at least two of the four preceding years. These groups pay a top-up tax if their effective tax rate in a country is below 15%.

As part of the Dutch tax changes 2027, the Netherlands implements the OECD Side-by-Side package of January 2026. The main proposals:

• Simplified ETR safe harbour: no top-up tax if a simplified effective tax rate, based on financial accounts, is at least 15%. Optional for fiscal years from 31 December 2025.
• Side-by-Side safe harbour: groups whose parent sits in a country with a recognised equivalent minimum tax are exempt from the Dutch IIR and UTPR, retroactive to 1 January 2026. The Dutch domestic top-up tax still applies.
• Substance-based tax incentive safe harbour: certain investment incentives, including Dutch deductions such as the EIA, count more favourably in the effective tax rate. The innovation box generally does not.
• Transitional CbCR safe harbour: extended by one year, to fiscal years starting before 31 December 2027.

For the filing side, see our article on Pillar Two reporting in the Netherlands.

“Most foreign groups read a Dutch tax plan for rate changes, and this year there are none. The money is in the incentives. A Dutch development team that qualifies for WBSO can now shelter up to €100,000 a year in the innovation box, and many subsidiaries never claim it because head office does not know it exists.”

How will the 2027 tax changes affect your financial planning?

The Dutch tax changes 2027 affect tax provisions, investment budgets, profitability and cash flow. Plan with two scenarios until the Senate votes in December 2026.

For a foreign-owned Dutch entity the effect of the Dutch tax changes 2027 shows up in four places in your financial planning:

• Tax provisions: with unchanged rates the provision stays largely the same, but an innovation box or EIA claim can lower your 2027 corporate tax substantially. Book it in your forecast only once the measure is adopted.
• Investment budgets: the higher EIA makes energy investments cheaper after tax. Timing matters, because the allowance applies in the year of investment and the budget is limited.
• Profitability: the unindexed €200,000 bracket means a slowly rising effective rate for growing companies.
• Cash flow: provisional assessments for 2027 are based on your estimate. Update it once the law is final, so you do not prepay too much tax.

The practical answer is scenario planning: run your 2027 forecast once with the proposals adopted and once without, and decide which investments only make sense in the first scenario.

How can foreign companies prepare for the Dutch tax changes?

To prepare for the Dutch tax changes 2027, check your tax exposure, innovation work, energy investments, payroll and Pillar Two position, then update your forecast once the law is final.

Use this checklist before the end of 2026:

1. Check your tax exposure: confirm whether you have a Dutch subsidiary, a permanent establishment or only sales, and which taxes apply to each.
2. Review innovation work: if you develop software or products in the Netherlands, check whether a WBSO declaration and the innovation box forfait apply.
3. List planned energy investments: check them against the Energy List and plan the EIA application within three months of the investment commitment.
4. Update payroll: apply the 27% expat scheme and the new salary norms from January 2027.
5. Test Pillar Two: if your group is near €750 million revenue, check whether a safe harbour applies.
6. Update your forecast: adjust tax provisions, provisional assessments and cash flow once the Senate has voted in December.

A financial controller keeps the provisions and assessments right month by month, while a CFO decides which scenarios to plan for and which investments to bring forward.

How Oakhill helps with the 2027 tax changes

Oakhill combines international tax services and CFO support, so the Dutch tax changes 2027 end up in your forecast and monthly figures.

Oakhill supports foreign companies operating in the Netherlands with international tax services and CFO services under one roof. We translate the Dutch tax changes 2027 into your figures: the effect on your corporate tax, the value of incentives you may be missing, and an updated forecast your head office can rely on. Our financial reporting then keeps the provisions in your monthly figures up to date.

Frequently asked questions about the Dutch tax changes 2027

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This article is general information, not tax or legal advice. Proposed measures can still change during the parliamentary process. Contact Oakhill Financial Services for advice on your own situation.