Budget Day: Tax Plan 2025 and Upcoming Changes

Sep 20, 2024

The Dutch Minister of Finance presented the 2025 budget to the parliament on 17 September. A number of changes are anticipated as part of the Tax Plan 2025.

 

Some of the most significant proposed changes include:

  • New group definition in the Withholding Tax Act;
  • Extension of the definition of a related party in the CIT Act;
  • Implementation of the OECD Pillar II guidelines in the Minimum Tax Act;
  • Correction of provisions on deductibility of interest payments in the CIT Act;
  • Abolition of the reduced VAT rate for certain transactions;
  • Partial reversal of the restrictions in the 30% allowance scheme.

 

In addition, a number of new provisions take effect from 1 January 2025, including:

  • Changing the fiscal classification of the so-called open limited partnerships, which will be treated as transparent for CIT purposes;
  • Tightening of the regime for exempt investment entities (VBIs) by excluding family structures;
  • Exclusion of direct investments in Dutch real estate from the fiscal investment units (FBI) regime;
  • Introduction of Country-by-Country Reporting for the largest multinationals;
  • Abolition of the partial foreign taxpayer status which entitled Dutch tax residents to Box 2 & 3 exemptions.

 

Do not hesitate to contact us should you require a detailed analysis of the issues of your particular interest.