Which important tax proposals relevant for corporates and high-net worth individuals are expected to be published?

Tax Plan 2024 and Other Tax Measures 2024

On Dutch Budget Day the standard tax proposals are the so-called Tax Plan 2024 as well as the Other Tax Measures 2024. These proposals contain various budgetary measures and consumer purchasing power measures. In addition, usually certain errata in tax legislation are repaired. As an example, certain amendments will be made to the temporary wealth tax legislation for individuals (see this article in Dutch for more background information). We note that a proposal for a completely new wealth tax system is currently open for consultation and is aimed to enter into force per 1 January 2027 under a new formed government after the elections. See for more information our newsletter (in Dutch).

We specifically mention three further announced measures that, if adopted, will enter into force per 1 January 2024:

  • A real estate transfer tax measure on share deals. See our earlier website post for more background information.
  • Following a recent Supreme Court case, the tax regime for so-called carried interest will be repaired.
  • Introduction of additional anti-dividend stripping legislation. See our earlier website post.
Legislative proposals regarding classification rules, funds for joint accounts and Dutch REITs

From the ten additionally announced bills to be submitted on Budget Day, we particularly highlight three measures that will impact, amongst others, the fund industry and corporates and will enter into force per 1 January 2025:

  1. A legislative proposal to overhaul the current Dutch tax classification rules for Dutch and foreign entities, such as partnerships. We refer to our earlier publication in this regard.
  2. A separate legislative proposal with respect to the definition of funds for joint account and the so-called tax-exempt entity regime (VBI-regime). See for more information this website post.
  3. Furthermore, a legislative proposal be submitted disallowing Dutch fiscal investment institutions (FBIs) to directly invest in real estate. We have discussed the alteration of the Dutch REIT-regime.

What is the potential effect of the caretaker government and the upcoming elections?

After the resignation of the Dutch cabinet this summer, the government became demissionary. A caretaker government remains in place until a new government has been formed after the elections.

A caretaker government usually does not present new policies and does not take political decisions on controversial issues. Thus, the question came up whether the currently pending and expected tax proposals would by qualified as controversial. Recently it became clear that his is not the case and the expected tax proposals will be presented on Budget Day.

However, it cannot be ruled out that during the consideration of the various tax measures political parties aim to bend certain tax measures with the upcoming elections in mind.

Closing remarks

Once the tax plans are published on Budget Day, we will analyse the proposals in more detail and summarise the proposed measures and their potential impact for funds, corporates and high-net worth individuals. All our updates can be found on this website page.