The proposals contain the following real estate-related tax measures.

Reduction of RETT rate for residential real estate to 7%

As of 1 January 2027, the real estate transfer tax (RETT) rate applicable to the acquisition of residential real estate as investment property will be reduced from 8% to 7%. The reduction is intended to improve investment conditions in the rental housing market and to increase the supply of rental homes, including mid-rent homes. Accordingly, acquisitions of such residential real estate completed on or after 1 January 2027 will, in principle, be subject to RETT at a rate of 7% rather than 8%.

The reduced 7% RETT rate only applies to the acquisition of real estate that qualifies as a dwelling. For these purposes, a dwelling is real property that, at the time of transfer, is ‘in its nature fit for residential purposes’. The reduced 7% RETT rate also applies to the acquisition of any appurtenances (aanhorigheden) to a dwelling that are acquired together with that dwelling, whether or not from the same seller. A related construction, such as a parking space, garage box, storage unit or bicycle shed, qualifies as an appurtenance if it (i) belongs to the dwelling, (ii) is used by the occupant of the dwelling, and (iii) is subservient to the dwelling.

In addition, the acquisition of a property of which at least 90% of the floor area is, in its nature, intended for residential use qualifies in its entirety for the application of the reduced 7% RETT rate.

The reduced 7% RETT rate only applies if, at the time of acquisition, the acquired real estate is in its nature fit for residential purposes. Consequently, the reduced 7% RETT rate does not apply to the acquisition of existing non-residential real estate that will, after acquisition, be redeveloped or transformed into residential real estate.

Generally, the execution of the deed of transfer constitutes the RETT taxable event, and the date of execution is decisive for determining the applicable RETT rate.

Mid-rent housing subsidy scheme

From 2029 through 2033, EUR 100 million will be made available annually for a new mid-rent housing subsidy scheme. Investors may qualify for a subsidy of up to EUR 10,000 for each newly built mid-rent home. With this measure, the Government aims to stimulate the construction of mid-rent homes, as their development is currently often unprofitable.

Housing associations are not eligible for the new subsidy. They are expected to gain access to financing on favourable terms from 2028 onwards, following changes to European regulations. This may encourage housing associations to develop additional mid-rent homes.

The new subsidy follows earlier measures aimed at stimulating housing construction, including the Landlord Levy Reduction Scheme (Regeling Vermindering Verhuurderheffing) and the Startbouwimpuls scheme. Under these schemes, landlords and municipalities could receive financial support for housing projects. Both schemes have since ended.

RETT exemption for transfers between housing associations

A RETT exemption has been proposed for transfers of social housing (DAEB properties) between housing associations. The measure, which forms part of the Tax Plans 2027, would allow housing associations to transfer such properties to one another without RETT becoming due.

The measure is intended to facilitate cooperation within the housing association sector. According to the explanatory notes, it should become easier for housing associations to transfer housing portfolios and projects to other associations that are better placed to make the required investments. At the same time, the existing RETT exemption for transfers of public-benefit activities (taakoverdrachten) would largely be restored to its pre-2021 form. The exemption would no longer apply where the transfer is made for consideration. As a result, the new exemption would become the main route for RETT-free transfers of DAEB properties between housing associations.

Carve-out from the earnings stripping rule for housing associations

The Government has announced that housing associations will be excluded from the earnings stripping rule (Article 15b CITA). The earnings stripping rule is a general interest deduction limitation that restricts the deductibility of net borrowing costs exceeding a specified threshold. This measure is intended to strengthen the financial position of housing associations and support the implementation of the National Performance Agreements (Nationale Prestatieafspraken).

The Government notes that housing associations are expected to face a shortage of investment capacity through 2034. By excluding housing associations from the earnings stripping rule, additional borrowing capacity is expected to become available, which should facilitate more favourable financing conditions and support future housing development projects.

The proposed measure has not yet been included in the legislative text of the Tax Plans 2027 and is expected to be introduced through a separate amendment. The measure is expected to enter into force as of 1 January 2028.  

Increase in the Energy Investment Allowance

The deduction rate for the Energy Investment Allowance (EIA) is proposed to be increased from 40% to 45.5% as part of the Tax Plans 2027. The EIA, as well as the Environmental Investment Deduction (MIA) and the Arbitrary depreciation of environmental investments (Vamil), have previously been extended to at least 31 December 2028.