NETHERLANDS Trends and Developments Contributed by: Frans Sonneveldt and Mike Vrijmoed, Forvis Mazars NV
Introduction The Dutch tax landscape continues to undergo changes. In June 2025, the Dutch cabinet fell, and new elections were called for October 2025. Due to this political instability, there is uncertainty around current and future tax laws and policies. This uncer - tainty has a considerable impact on both businesses and individual taxpayers, who are eagerly awaiting potential new fiscal policies. In this article, we exam - ine recent trends and developments in Dutch tax law, with particular attention to the areas most relevant to high-net-worth individuals and their advisors. Personal Income Tax: A System in Motion The Dutch income tax system is divided into three “boxes”, each with its own tax rules and rates. Recently, we have seen significant changes, particu - larly aimed at preventing improper, according to the legislator, use and improving the fairness of the sys - tem. Box 1: income from work and home ownership Box 1 includes income from employment and home ownership. The tax rates in this box are progressive, with a maximum rate of 49.5% in 2025. Although no major changes have been announced for Box 1, it remains an area of focus for policy-makers striving for a balanced tax system. Will we see shifts in the future in the balance between labour and capital? Box 2: substantial shareholdings Box 2 concerns income from substantial sharehold - ings (at least 5%), which in practice often amounts to dividends and capital gains. Here we have seen significant recent changes. The rates were raised in recent years from a fixed rate of 25% to a two-bracket system. In 2025, box 2 contains the following brack - ets: • 24.5% on the first EUR 67,804 (EUR135,608 for
In recent years, there have been significant develop - ments in legislation around donations from compa - nies to Public Benefit Organisations (in Dutch: ANBIs). Donations by companies are deductible for corporate income tax up to EUR100,000 per year (with a maxi - mum of 50% of the profit). Only in 2024 were dona - tions by companies exempt from income tax in Box 2 and dividend withholding tax. In other words, when a company makes a significant donation in 2025 and onwards, this will be a deemed dividend to its share- holders. For individuals, it is still possible to get tax benefits by structuring the donation as a periodic gift (at least 5 years). Box 3: the fiscal Rubik’s cube for savings and investments Box 3, which taxes income from savings and invest - ments, has undergone the most turbulent period. In 2021, the Supreme Court ruled that the then Box 3 system was incompatible with European law. Since 1 January 2023, transitional legislation has been in effect, and when you think you have solved it, you are forced to think again. The current system works as follows: there is an exemption of EUR57,684 per person (2025). Sepa - rate notional returns are used for different asset cat - egories: • Savings: 1.44% • Investments and other assets: 5.88% • Debts: -2.62% (deductible). The calculated notional return is taxed at 36% (2025). Despite sharp criticism, the notional return on invest - ments and other assets will probably rise for 2026. In June 2024, the Supreme Court again ruled that the current system violates the prohibition of discrimina - tion and the property right. As a result, taxpayers must be allowed to demonstrate that their actual return is lower than the notional return, and in that case, pay tax on the lower actual return. Following that case law, in 2025, the temporary counter-evidence law for Box 3 took force. This law allows for demonstrating the actual return.
fiscal partners); and • 31% on the excess.
The measure that taxes debts to one’s own compa - ny above a certain threshold as deemed dividends remains applicable. For 2025, this occurs above a total loaning sum of EUR500,000.
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