For the fund industry the proposals on the extension of grandfathering rules for partnerships/FGRs, following new entity classification rules, and the increased Box 2 taxation for indirectly held lucrative interests are relevant. For corporate taxpayers the implementation of the latest OECD Pillar Two Guidance and the EU directive addressing the exchange of information on minimum taxation in the Minimum Tax Act 2024 (MTA 2024), is important. Below, these and some other measures are described in more detail. If approved, these changes enter into force per 1 January 2026, unless indicated otherwise.
Subsequently, we also address certain measures that were adopted last year but will enter into force per 1 January 2026 as well as the status of some other tax developments.
Corporate income taxes
Pillar Two
The law implementing Pillar Two in the Netherlands, the MTA 2024, has been enacted as of 31 December 2023. The Tax Plans 2026 contain two proposed acts in relation to the MTA 2024:
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- the Second Act amending the MTA 2024 (Tweede wet aanpassing Wet minimumbelasting 2024) implementing the latest OECD Pillar Two Guidance and making several technical changes; and
- the Act implementing the EU directive on exchange of information in relation to the global minimum tax (Wet implementatie EU-richtlijn gegevensuitwisseling minimumbelasting).
Personal income taxes and employment taxes
Tax measures related to energy and environment
There are several proposals related to specific energy and environmental taxes. These include:
- The introduction of a distance-based flight tax, replacing the current flat-rate tax.
- A significant increase in the water tax, which will be applicable to the supply of drinking water.
- A de facto abolishment of the CO2 levy for the industry, except for waste incineration where the levy is increased.
For more information on the proposed changes to these taxes, we refer to our website post of 16 September 2025: Dutch Budget Day 2025: Energy and Environment
VAT rate on culture, media and sports
The Tax Plans 2026 have reversed the Tax Plans 2025 proposal to increase the Dutch VAT rate for culture, media and sports from 9% to 21%. This means that the Dutch VAT rate on these supplies remains 9%.
Other legislation to come into effect as per 2026
Other relevant tax developments
We will keep you informed on further developments. Should you have any questions with respect to the above, please contact your trusted adviser.
