NETHERLANDS Law and Practice Contributed by: Friederike Henke, Ingrid Cools, Philip ter Burg, IJsbrand Uljée, Suzan van de Kam and Epke Spijkerman, BUREN
will not apply to applicants who already applied the 30% ruling before 1 January 2024. Employee social security contributions Individuals are subject to social security contributions levied on income up to and including EUR38,883. The
Non-Dutch tax-resident companies are subject to corporate income tax from certain Dutch sources, including: • Dutch permanent establishments or permanent representatives; • shareholdings of at least 5% in Dutch companies that cannot pass certain anti-abuse tests; and • other specific sources, including Dutch real estate, directorship services and the exploration of natural resources. The Dutch corporate income tax rate in 2026 is 19% for taxable profits up to and including EUR200,000, and 25.8% for taxable profits exceeding this amount. Under the Dutch participation exemption, income (eg, dividends and capital gains) derived by Dutch resi - dent corporate taxpayers from qualifying subsidiaries is exempt from Dutch corporate income tax. In 2026, the term of the loss carry forward facility is an unlimited period. The carry back period is one year. Profits of up to EUR1 million can be fully deducted under the application of the loss carry forward and backward facility. For profits exceeding EUR1 million, only 50% of the profit can be reduced under these facilities. Minimum Profit Tax In line with EU regulation, the Netherlands has intro - duced a Minimum Profit Tax Act: Wet Minimumbelast - ing 2024. The act requires large multinational enter - prises with an annual turnover exceeding EUR750 million to be subject to (at least) 15% minimum tax due to the so-called OECD Pillar 2 project. Dividend Withholding Tax Shareholders of Dutch tax-resident companies are generally subject to 15% Dutch dividend withhold - ing tax in respect of dividends (and other payments treated as dividends) paid by Dutch tax resident com - panies (or companies deemed to be tax residents). In principle, distributing companies should withhold and pay any Dutch dividend withholding tax due. An exemption applies to dividends distributed to cor - porate shareholders owning a share interest of at least
applicable rate is 27.65%. Taxes Paid by Employers Wage tax
Employers qualifying as “withholding agents” must withhold wage tax and social security contributions (levied at the level of employees) in respect of wages paid to employees for Dutch wage tax purposes. Employer social security contributions In summary, the rates of employer social security con - tributions in 2026 are as follows. • General unemployment insurance ( Algemeen werkloosheidsfonds – AWF) – 2.74% for contracted workers with an indefinite term and 7.74% for flex workers and temporary workers. • Occupational disability insurance ( Wet op de arbeidsongeschiktheidsverzekering – WAO or Wet werk en inkomen naar arbeidsvermogen – WIA) – 7.61% for large employers and 6.26% for small employers. • Health Insurance Act contribution ( Zorgverzekering- swet – ZVW) – 6.10%. • Childcare allowance contribution ( Werkgeversbi- jdrage Kinderopvang ): 0.5%. • Government unemployment insurance ( Uitvoer- ingsfonds voor de overheid – UFO) – 0.68%. • The Return to Work Fund ( Werkhervattingskas – Whk) – 1.52% (approximate amount). Only income up to and including EUR79,409 is subject to the above contributions. 5.2 Taxes Applicable to Businesses Corporate Income Tax Dutch tax-resident companies (or companies deemed to be tax residents) are subject to Dutch corporate income tax based on their worldwide income.
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