Personal and business taxation in the Netherlands

Documentary position as at 5 October 2026. The reference points cover the tax years 2025 and 2026 (calendar years) and rely on the consolidated texts on wetten.overheid.nl, the pages of the tax administration (Belastingdienst) and the judgments of the Hoge Raad. Measures enacted for 2027 and bills under discussion are flagged as such. Amounts in euros.

1. Identifying the year, the tax and the taxpayer

1. Income tax (inkomstenbelasting) is governed by the Wet inkomstenbelasting 2001 (Wet IB 2001). Its Article 2.3 charges the income of the calendar year, divided into three tax bases: income from work and home ownership (box 1), income from a substantial interest (aanmerkelijk belang, box 2) and income from savings and investments (sparen en beleggen, box 3). Each box has its own rules and its own rate, and a box 1 loss cannot be set off against another box, according to the Belastingdienst. S02S06

2. Article 2.1 of the Wet IB 2001 distinguishes residents (binnenlandse belastingplichtigen), who live in the Netherlands, from non-residents (buitenlandse belastingplichtigen), who receive Dutch income there within the meaning of Chapter 7. According to the Belastingdienst, a resident declares his or her worldwide income, double taxation being eliminated by a tax reduction, and a non-resident only his or her income taxable in the Netherlands. S02S30

3. The first band of box 1 includes, in addition to income tax, national insurance contributions (premie volksverzekeringen), levied together with the tax as a single amount according to the Belastingdienst. The statutory scale in Article 2.10 of the Wet IB 2001 covers only the tax component. S02S04S30

4. The other levies fall under separate Acts: corporate income tax (Wet op de vennootschapsbelasting 1969), dividend withholding tax (Wet op de dividendbelasting 1965), conditional withholding tax (Wet bronbelasting 2021), minimum tax (Wet minimumbelasting 2024), VAT (Wet op de omzetbelasting 1968), transfer tax (Wet op belastingen van rechtsverkeer) and inheritance and gift tax (Successiewet 1956). The common rules, including those on domicile, are laid down in the Algemene wet inzake rijksbelastingen (AWR). S01S32S35S38S42S44S46S51

2. Residence of individuals and companies

5. Article 4(1) of the AWR provides that where a person lives, and where an entity is established, is assessed according to the circumstances (naar de omstandigheden). The text sets neither a threshold in days nor any numerical criterion: residence results from a body of factual indicators. S01

6. Article 2.2 of the Wet IB 2001 deems a person who leaves the Netherlands and returns within the year without having lived in another State to have lived in the Netherlands during his or her absence. The fiction does not apply if the person concerned establishes that he or she was taxed as a resident in a Member State of the Union, or in a designated treaty State providing for exchange of information, on substantially equivalent bases. S02

7. For an entity, Article 2(5) of the corporate income tax Act adds a fiction to this criterion: an entity incorporated under Dutch law is always deemed to be established in the Netherlands, except for certain exhaustively listed provisions, including the participation exemption regime. A company incorporated under Dutch law and managed from abroad therefore remains, under domestic law, a resident taxpayer. S01S38

8. Where France and the Netherlands both regard an individual as resident, Article 4(3) of the treaty of 16 March 1973 applies successively the permanent home, the centre of vital interests, the habitual abode and then nationality, before agreement between the competent authorities. For a person other than an individual, Article 4(4) applies the place of effective management. S55

9. Arrival or departure during the year results in partial residence: for box 3, Article 5.2(6) of the Wet IB 2001 takes the base at the beginning of the year but reduces the benefit pro rata to the period of tax liability, and Article 2.7(2) reduces the general tax reductions (heffingskortingen) pro rata temporis. S02

3. Income tax: the three-box system and the 2025-2026 scales

10. Box 1 includes in particular business profits, salaries, pensions and social security benefits, income from other activities, certain periodic annuities and the notional income from the main residence (eigenwoningforfait). Deducted from it are, among other things, the deductible costs of the main residence, annuity premiums and personal deductions. S04S06

11. For 2025, the Belastingdienst publishes the following overall scale for persons below the state pension age (AOW). The tax component of the first band set by Article 2.10 of the Wet IB 2001 in its version applicable on 1 January 2025 is 8.17%, the remainder corresponding to national insurance contributions. S03S05

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Box 1 taxable income (2025, below AOW age)Overall rateSources
Up to EUR 38,44135.82%S03S05
From EUR 38,441 to EUR 76,81737.48%S03S05
Above EUR 76,81749.50%S03S05

12. For 2026, the first band is raised to EUR 38,883 and the second to EUR 78,426. The tax component of the first band in consolidated Article 2.10 is 8.10%. The Belastingdienst publishes the following overall rates for persons below AOW age. S02S04S06

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Box 1 taxable income (2026, below AOW age)Overall rateSources
Up to EUR 38,88335.75%S02S04S06
From EUR 38,883 to EUR 78,42637.56%S02S04S06
Above EUR 78,42649.50%S02S04S06

13. For 2026, the Belastingdienst indicates 17.85% up to EUR 41,123 for persons who have reached AOW age and were born before 1 January 1946, and a first-band rate that varies according to the month in the year in which that age is reached. For persons born in or after 1946 who have reached that age, the box 1 page and the explanatory memorandum to the Belastingplan 2027 indicate 17.85% up to EUR 38,883; the table in Fiscale informatie 2026, which shows 35.75% for this category, is not used. S04S06S59

14. Article 2.10(2) and (3) of the Wet IB 2001 limits the benefit of certain deductions (main residence costs, entrepreneur's deduction, personal deductions): the tax is increased by 11.94% of the portion of those deductions relating to income exceeding the threshold of the last band, i.e. EUR 78,426 in 2026 according to the Belastingdienst (tariefsaanpassing aftrekposten). S02S04

15. Box 2 covers income from a substantial interest, held under Article 4.6 of the Wet IB 2001 where the taxpayer owns, alone or together with his or her fiscal partner, directly or indirectly, at least 5% of the issued capital of a company, rights to acquire 5% of that capital or profit-sharing certificates relating to 5% of the profit. Dividends and capital gains fall within it, while the salary paid by the company remains in box 1. S02S07

16. The box 2 rate has two bands, set by Article 2.12 of the Wet IB 2001. The Belastingdienst illustrates the 2026 scale with a dividend of EUR 70,000: 24.5% on EUR 68,843, i.e. EUR 16,866, then 31% on EUR 1,157, i.e. EUR 358, for a total of EUR 17,224. S02S03S07

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Box 2 income20252026Sources
First band24.5% up to EUR 67,80424.5% up to EUR 68,843S02S03S07
Above31%31%S02S03S07

17. The Belastingdienst's 2025 tax return guide mentions for box 2 a threshold of EUR 67,000 and a rate of 33%, figures that the box 2 page attaches to 2024; for 2025, this factsheet relies on Article 2.12 then in force and on that page, which agree on EUR 67,804 and 31%. S03S05S07

18. Dividend withholding tax and wage tax (loonbelasting) are prepayments (voorheffingen) creditable against income tax (Article 9.2 of the Wet IB 2001), subject to the conditions it lays down for dividend withholding tax. Box 3, taxed at 36% (Article 2.13), is presented in the next section. S02S04S08S32

19. The Belastingplan 2027 bill, published online by the government in the file of 15 September 2026, proposes a first box 1 band up to EUR 39,247 with a tax component of 8.58%. This text had not been adopted at the date of consultation. S59

4. Box 3: from the deemed return to the Hoge Raad judgments and the ongoing reform

20. From 2017 to 2022, box 3 was based on a deemed return on net assets at 1 January, divided by bands between presumed savings and presumed investments. For 2021, the presumed average return ranged from 1.898% to 5.69% depending on the band, and the tax was 31%, according to the Belastingdienst. S09

21. By its judgment of 24 December 2021 (ECLI:NL:HR:2021:1963), known as the “Kerstarrest”, the Hoge Raad held that the deemed-return box 3 regime for 2017 and 2018 was contrary to Article 1 of the First Protocol to the European Convention on Human Rights taken in conjunction with Article 14 thereof (non-discrimination). The Court granted redress consisting in taxing only the return actually obtained on the box 3 assets. S10

22. The Act of 21 December 2022 on the restoration of rights in box 3 (Wet rechtsherstel box 3) lowers the taxable benefit for 2017 to 2022 where necessary to comply with that judgment. According to the Hoge Raad, this text retains a deemed calculation but introduces a specific return for bank balances; for 2021 and 2022, the Belastingdienst applies the more favourable of the two methods. S09S11S13

23. By its judgment of 6 June 2024 (ECLI:NL:HR:2024:704), the Hoge Raad held that the regime resulting from the Wet rechtsherstel box 3 also infringes the same provisions where it leads to taxing a benefit higher than the actual return, whatever the size of the difference. The Court noted that the bridging Act (Overbruggingswet box 3) follows the method of the restoration Act as far as possible, pending a regime based, as a general rule, on the actual return. S11

24. The same judgment defines the actual return. It is measured on all box 3 assets, including bank balances, without deduction of the tax-free allowance (heffingvrij vermogen). It includes current income, such as interest, dividends and rents, as well as positive and negative changes in value, even if unrealised. It is nominal and is determined year by year. S11

25. The Act of 14 July 2025 introducing rebuttal evidence in box 3 (Wet tegenbewijsregeling box 3) enshrined this solution in Article 5.25 of the Wet IB 2001: where the taxpayer establishes an actual return lower than the deemed benefit, box 3 taxable income is set at that actual return, with a minimum of zero. Articles I and III of the Act apply retroactively from 1 January 2023 and its Article IV, which amends the restoration Act, from 1 January 2017. S02S14

26. Article 5.26 of the Wet IB 2001 defines the actual return as the sum of current income and capital growth (vermogensaanwas), which, under Article 5.28, is the change in the net value of assets and debts over the year, reduced by contributions and increased by withdrawals. The Belastingdienst specifies that costs are in principle not deductible, except interest on box 3 debts and certain investments in a second home. S02S05

27. Under the transitional regime, the deemed benefit in Article 5.2 of the Wet IB 2001 applies a specific return to each category of actual assets at 1 January; the resulting effective rate is applied to the portion of the base exceeding the tax-free allowance. The rates are replaced each year by ministerial order pursuant to Article 10.6ter, those for bank balances and debts being set after the end of the year. S02S04S08

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Category (box 3, deemed-return regime)20252026Sources
Bank balances and cash1.37%1.28% (provisional)S04S05S08
Investments and other assets5.88%6.00%S04S05S08
Debts2.70%2.70% (provisional)S04S05S08
Tax-free allowance per personEUR 57,684EUR 59,357S02S03S04S08

28. For 2026, the Belastingdienst specifies that the investment rate is final and that the rates for bank balances and debts will be set at the beginning of 2027. It illustrates the calculation for EUR 150,000 of savings without a partner: return of EUR 1,920, base of EUR 90,643, benefit of EUR 1,160 and tax of EUR 417. The annual figures used here are those of these pages: the consolidated version in force of Article 5.2 shows the 2025 rates (1.37% and 2.70%) resulting from the retroactive replacement published in Staatscourant 2026, 3708, according to the note to the 2025 version. S02S03S08

29. The investments category includes in particular shares, bonds, receivables, crypto-assets, second homes and let dwellings. Debts are taken into account only above a threshold (drempel), not quantified here, and fiscal partners combine their tax-free allowances and allocate the base freely. S04S08

30. By its judgment of 25 June 2026 (ECLI:NL:HR:2026:907), the Hoge Raad dismissed the appeal in cassation of a taxpayer who had not challenged his or her assessments for 2017 to 2020, which are not reduced, non-objectors not being in the same situation as objectors. S12

31. The bill on actual return in box 3 (Wet werkelijk rendement box 3, file 36748) is intended to replace the transitional regime with a tax on capital growth (vermogensaanwasbelasting) from 1 January 2028, according to the government, which indicated on 19 June 2026 that the bill would remain the basis for that regime, with adjustments possibly being included in the Belastingplan 2027. S15S16

32. The bill was passed by the Second Chamber on 12 February 2026. According to the First Chamber's file, after the sitting of 30 June 2026, postponement of the vote until one or more amending bills (novelle) have been considered was requested, and a motion not opposing the withdrawal of the bill was rejected on 7 July 2026. No final adoption appears in the sources consulted as at 5 October 2026. S16S17S18

5. Regime for inbound expatriates: the 30% ruling and its reduction

33. The expatriate scheme (expatregeling, commonly known as the 30% ruling) is based on Article 31a(8) of the wage tax Act (Wet op de loonbelasting 1964). For the categories of employees recruited from outside the Netherlands designated by regulation, the allowance for extraterritorial costs (extraterritoriale kosten) is deemed, for a maximum of five years, to cover costs up to a maximum of 30% of the designated portion of the salary, in addition to designated school fees. According to the Belastingdienst, the employer can thus pay this amount tax-free without substantiating the actual costs. S20S23

34. The same paragraph caps the exempt amount at 30% of the maximum salary provided for by the Act on standards for senior public-sector remuneration (Wet normering topinkomens). The Belastingdienst indicates for 2026 a maximum exempt allowance of EUR 78,600, reached for a salary of EUR 262,000 or more and application over the full year; the cap is prorated in the event of partial application. According to the Rijksoverheid, this cap has applied to all expatriates since 2026. S20S22S23S24

35. The conditions are set out in Articles 10e to 10ej of the implementing decree (Uitvoeringsbesluit loonbelasting 1965): recruitment abroad or posting from abroad, specific expertise that is scarce on the Dutch market and residence, for more than two thirds of the twenty-four months preceding the employment, more than 150 kilometres from the border. According to the Belastingdienst, this condition excludes persons coming from Belgium, Luxembourg and parts of Germany, France or the United Kingdom. S19S22

36. Expertise is presumed above a salary threshold excluding the allowance (Article 10eb of the decree), from which certain researchers and doctors in specialist training are exempted. S19S22

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Annual salary threshold (excluding the allowance)20252026Sources
General caseEUR 46,660EUR 48,013S19S22
Under 30 holding a master's degreeEUR 35,468EUR 36,497S19S22

37. The five-year period is reduced by earlier periods of work or stay in the Netherlands, unless they ended more than twenty-five years earlier or remain within the tolerances of Article 10ef of the decree. The joint application by the employer and the employee takes effect from the start of the employment if it is filed within four months; otherwise, the period is reduced by the time elapsed. S19S22

38. The enacted Act provides for a reduction of the rate. The version of Article 31a(8) applicable from 1 January 2027, published on wetten.overheid.nl as a future text, replaces 30% with 27%, including for the cap calculated on the maximum public-sector salary. The Rijksoverheid indicates that a higher salary threshold will also apply in 2027, without giving its amount on the page consulted. S21S24

39. The Rijksoverheid presents the transitional regime: decision applied not later than 31 December 2023, 30% and the current threshold maintained in 2027 and beyond; application in 2024, 27% in 2027 with the current threshold; application from 2025, 27% and new threshold in 2027. The table links the 2027 regime to the date on which the decision was first applied; the Kennisgroep (KG:041:2024:11) has clarified the notion of actual application, by pay periods, only for the 2024 and 2025 transitional measures, without taking a position on the move to 27%. S24S26

40. A declining 30-20-10 sequence (30%, then 20%, then 10%, by periods of twenty months) had been introduced on 1 January 2024 in Article 10ea of the decree. The Kennisgroep withdrew its position on this point, this tightening having been largely abandoned on 1 January 2025 by the Belastingplan 2025; the consolidated text of Article 10ea consulted still mentions this sequence, an interaction not resolved in the sources read. S19S25

41. The option for partial non-resident tax liability (partiële buitenlandse belastingplicht) has been abolished: Article 2.6 of the Wet IB 2001 is shown as repealed as of 1 January 2025, the Kennisgroep linking the transitional measure to application of the scheme in the pay period ending on 31 December 2023. S02S26

6. Departure from the Netherlands: conserverende aanslag and aanmerkelijk belang

42. Article 4.16(1)(h) of the Wet IB 2001 treats as a disposal of the shares forming a substantial interest the termination, other than by death, of tax liability as a resident, including where the taxpayer ceases to be a Dutch resident within the meaning of a tax treaty. The unrealised gain in box 2 is therefore recognised on departure. S02

43. The corresponding tax is the subject of a protective assessment (conserverende aanslag). Under Articles 2.8 and 2.9 of the Wet IB 2001, this income “to be preserved” is excluded from ordinary taxation and gives rise to a separate assessment, equal to the difference between the tax calculated with and without that income, with a minimum equal to the tax that would be due if that income were the only income. The Belastingdienst specifies that the income to be preserved is subject to the highest rate. S02S27

44. According to the Belastingdienst, a protective assessment generally has a validity period of ten years, except for one relating to a substantial interest, which is not limited in time. Where deregistration from the municipal register took place after 15 September 2015 at 15:15, the deferral of payment of the tax on the substantial interest is for life and is no longer remitted after ten years, whereas a departure before that time gave entitlement to a ten-year deferral followed by remission on request. S27

45. Deferral of payment is granted automatically and without collection interest in the event of departure to a Member State of the European Union or of the European Economic Area. Outside the Union and the European Economic Area, deferral is not automatic and must be requested; in the event of departure to a State that is not a member of the Union, security must in principle be provided for the tax relating to the substantial interest, except for departure to Norway, Iceland or Liechtenstein. Deferral is withdrawn in the event of a subsequent move from a Union State to a third State, the taxpayer then being able to apply for a new one. S27

46. Article 25(8) of the Collection Act (Invorderingswet 1990) refers to a ministerial order for the rules on the deferral relating to preserved box 2 income and provides that the deferral ends in particular on a disposal, within the meaning of the Wet IB 2001, of the shares concerned. The Belastingdienst adds that the sale of the shares, the distribution of a dividend or the cessation of the business must be reported and trigger full or partial payment. S27S29

47. Departure also triggers a protective assessment on pensions and annuities built up with deduction and on certain savings products linked to the main residence, remitted after ten years on request if the Dutch rules have been complied with, according to the Belastingdienst. S27S28

7. Non-residents and withholding taxes

48. A non-resident is taxed only on his or her Dutch income (Article 7.1 of the Wet IB 2001): in box 1, in particular the profits of a permanent establishment and salaries from work performed in the Netherlands; in box 2, income from a substantial interest in a company established in the Netherlands; in box 3, certain Dutch assets. S02

49. The box 3 of a non-resident is limited by Article 7.7 of the Wet IB 2001 to immovable property situated in the Netherlands, rights relating thereto and certain rights to the profits of an enterprise managed in the Netherlands. The Belastingdienst confirms that a Dutch bank account or an annuity insurance policy taken out in the Netherlands is not taxed, whereas a holiday home or a let property is, 1 January remaining the reference date. S02S31

50. A qualifying non-resident taxpayer (kwalificerende buitenlandse belastingplichtige) is, under Article 7.8(6) of the Wet IB 2001, a resident of the Union, the EEA, Switzerland or the BES islands whose income, alone or together with that of his or her partner, is taxed wholly or almost wholly in the Netherlands. According to the Belastingdienst, he or she is entitled to the deductions, tax reductions and tax-free allowance of a resident. S02S30

51. Dividend withholding tax (dividendbelasting) is levied, at the rate of 15% set by Article 5 of the Wet op de dividendbelasting 1965, on the proceeds of shares and units in companies established in the Netherlands. It is withheld by the distributing company when the proceeds are made available (Article 7). If the company bears the withholding tax itself, the base is grossed up by 100/85 (Article 6). S32S33

52. Article 4(2) of the same Act exempts from withholding dividends paid to an entity established in another Member State of the Union or of the European Economic Area, or in a treaty State whose treaty provides for rules on dividends, where that entity holds an interest that would qualify for the participation exemption if it were established in the Netherlands. The Belastingdienst describes as a participation dividend a dividend paid to an entity holding at least 5% of the shares and indicates that, for a shareholder established outside the Netherlands in a State without a treaty, the 15% withholding tax applies; Article 4(2) does not require a treaty where the recipient is established in the Union or the European Economic Area. S32S33S34

53. Under Article 4(3), the exemption does not apply where the recipient is deemed to be established, within the meaning of a treaty, in a third State that has no treaty with the Netherlands, where it performs a function comparable to that of an investment institution, or where it holds the interest with the main purpose, or one of the main purposes, of avoiding tax payable by another person in the context of an artificial arrangement. Paragraph 4 requires proof of beneficial ownership. S32

54. Where the exemption does not apply but a treaty reduces the rate, the Belastingdienst requires prior authorisation, on written application, to apply the treaty rate at source. S34

55. The Wet bronbelasting 2021, in force since 2021, introduces a conditional withholding tax on interest and royalties paid by a Dutch entity to a related entity established in a low-tax jurisdiction or in certain abusive situations. The Act of 4 November 2021 extended it to dividends from 1 January 2024. The rate is equal to the highest corporate income tax rate, i.e. 25.8% in 2024, 2025 and 2026 according to the Belastingdienst. S35S36S37

56. Under Article 1.2 of the Wet bronbelasting 2021, a low-tax jurisdiction is a State designated by ministerial order which, on 1 October of the preceding year, does not tax profits or taxes them at less than 9%, or which appears on the Union list of non-cooperative jurisdictions. According to the Belastingdienst, the relationship exists in particular above 50% of the voting rights, and dividend withholding tax is credited against the conditional withholding tax (Article 5.2). S35S37

57. No general withholding tax on interest and royalties paid to unrelated persons has been identified in the texts consulted, the Wet bronbelasting 2021 covering only payments to related entities in the situations it lists. S35

8. Companies: vennootschapsbelasting, participations and Pillar Two

58. Corporate income tax (vennootschapsbelasting) is levied on the entities established in the Netherlands listed in Article 2 of the 1969 Act, in particular public limited companies (NV), private limited companies (BV), cooperatives and mutual funds. The Belastingdienst specifies that foundations and associations are taxable only if they carry on a business. S30S38

59. Article 22 of the Act sets a two-band scale, unchanged from 2023 to 2026 according to the Belastingdienst. S38S39S40

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Taxable profit (vennootschapsbelasting)Rates for 2025 and 2026Sources
Up to EUR 200,00019%S38S39S40
Above EUR 200,00025.8%S38S39S40

60. Article 15b of the Act limits the deduction of net interest expense to the higher of two amounts: 24.5% of adjusted profit or EUR 1,000,000; according to the Belastingdienst, the excess can be carried forward to subsequent years. S38S40

61. The participation exemption regime (deelnemingsvrijstelling) in Article 13 excludes from profit the benefits derived from a participation, as well as the costs of acquiring or disposing of it. A participation exists in particular where the taxpayer holds at least 5% of the paid-up nominal capital of a company with share capital, at least 5% of the units of a mutual fund, or membership of a cooperative. According to the Belastingdienst, a participation of at least 5% held for more than one year that falls below that threshold retains the regime for three years. S38S41

62. Under Article 13(9), the exemption does not apply to a participation held as a portfolio investment (beleggingsdeelneming), unless it is a qualifying portfolio participation. Paragraph 11 sets out two criteria: taxation of the subsidiary's profits that is real by Dutch standards, and assets consisting, as a general rule, of less than half of low-taxed free portfolio investments; the local extract does not show the word linking them, a point to be checked against the official publication. S38

63. The 2024 minimum tax Act (Wet minimumbelasting 2024) transposes Directive (EU) 2022/2523. It covers entities of multinational and domestic groups whose consolidated revenue amounts to at least EUR 750,000,000 in at least two of the four preceding financial years, and sets a minimum rate of 15%. It entered into force on 31 December 2023 for financial years beginning on or after that date, certain amending provisions (Articles 15.1 and 15.2, under A) applying to financial years beginning on or after 31 December 2024. S42S43

64. According to the Belastingdienst, the difference between a country's effective rate and 15% gives rise to a top-up tax (bijheffing); the information return is due within fifteen months after the end of the financial year (eighteen for the first financial year) and the tax return within seventeen months (twenty for the first financial year). S43

9. VAT (BTW)

65. VAT (omzetbelasting, commonly BTW) is governed by the Wet op de omzetbelasting 1968, Article 9 of which sets the standard rate at 21%, a reduced rate of 9% for the goods and services in Table I annexed to the Act and a zero rate for those in Table II, subject to regulatory conditions. Article 20 applies the same rates of 21% and 9% to imports of the goods concerned. S44S45

66. Article 11 in principle exempts the supply of immovable property, except in particular the supply of a building before, upon or within two years following its first occupation, and that of building land, an option to tax being available subject to conditions. Article 25a allows an entrepreneur established in the Netherlands whose annual Dutch turnover does not exceed EUR 20,000 to opt for the small business exemption (kleineondernemersregeling). S44

10. Real estate: overdrachtsbelasting and local taxes

67. Real estate transfer tax (overdrachtsbelasting) is governed by the Wet op belastingen van rechtsverkeer. Article 14 thereof sets a general rate of 10.4%, a rate of 8% for the acquisition of a dwelling, and a rate of 2% for the acquisition by an individual of a dwelling that he or she will use on a lasting basis as main residence, subject to a prior written declaration. S46S47

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Situation (overdrachtsbelasting)20252026Sources
Dwelling occupied by the acquirer2%2%S46S47
First-time buyer under 35, conditions met0%0%S46S47S48
Dwelling not occupied by the acquirer (second home, letting, investment)10.4%8%S46S47
Other immovable property (business premises, land, garage acquired separately)10.4%10.4%S46S47

68. The first-time buyer exemption (startersvrijstelling) in Article 15(1)(p) requires the acquirer to be of full age and under 35 years of age, never to have benefited from the exemption, to declare in writing before the acquisition that he or she will occupy the dwelling on a lasting basis as main residence, and the value of the dwelling and its appurtenances not to exceed EUR 555,000. The Belastingdienst specifies that the cap is assessed on the total value of the dwelling, and not on the share acquired. S46S48

69. Under Article 220 of the Municipalities Act (Gemeentewet), municipalities may levy property taxes (onroerende-zaakbelastingen, OZB) on holders of a right of ownership, of possession or of a right in rem and, for property not mainly used as a dwelling, on users. The base is the WOZ value (Wet waardering onroerende zaken); municipal rates are not reproduced here. S49S50

70. The Rijksoverheid specifies that the same WOZ value is also used by the tax administration for the notional income from the main residence and for gift and inheritance tax. Immovable property other than the main residence falls within box 3, in the case of a non-resident if it is situated in the Netherlands. S08S31S50

11. Wealth, inheritances and gifts

71. No annual wealth tax on individuals has been identified in the texts consulted; wealth is captured through box 3. The 1973 treaty still refers to a Dutch wealth tax (vermogensbelasting), a reference not reconciled here with current law. S02S55

72. The Successiewet 1956 introduces an inheritance tax (erfbelasting) on assets acquired on the death of a person who lived in the Netherlands and a gift tax (schenkbelasting) on assets received from a donor who lived there (Article 1). The criterion is the residence of the deceased or the donor, not that of the beneficiary; the passages read do not provide for taxation of the Dutch assets of a non-resident deceased. S51

73. Article 3(1) of the Successiewet 1956 deems a Dutch national who lived in the Netherlands and dies or makes a gift within ten years of leaving to be resident at the time of death or of the gift. Paragraph 2 additionally deems resident, for gifts only, any person who lived in the Netherlands and makes a gift within the year following departure. A Dutch national settled in France therefore remains exposed to Dutch inheritance and gift tax for ten years. S51

74. The rate in Article 24 has two bands and two columns of beneficiaries, descendants in the second degree or further bearing the children's rate increased by 80%. The Belastingdienst publishes the following 2026 rates, applicable after deduction of the allowance. S51S52

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Taxable share (2026)Partner and childrenGrandchildren and further descendantsOther beneficiariesSources
Up to EUR 158,66910%18%30%S51S52
Above EUR 158,66920%36%40%S51S52

75. Inheritance tax allowances are set by Article 32 of the Successiewet 1956. According to the Belastingdienst, the partner for tax purposes includes the spouse, the registered partner and the cohabiting partner, subject to the conditions it specifies. S51S53

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Inheritance tax allowance (2026)AmountSources
Spouse or partnerEUR 828,035S51S53
Child, foster child or stepchildEUR 26,230S51S53
Dependent child whose earning capacity is reduced under the statutory conditionsEUR 78,671S51S53
GrandchildEUR 26,230S51S53
ParentEUR 62,110S51S53
Other beneficiaryEUR 2,769S51S53

76. For gifts, Article 33 exempts EUR 6,908 for a gift from parents to a child, an annual amount according to the Belastingdienst, and EUR 2,769 in other cases. Between 18 and 40 years of age, the child may benefit once from EUR 33,129, or EUR 69,009 for expensive studies; the increased allowance for housing no longer exists since 1 January 2024. S51S54

77. No Franco-Dutch treaty on inheritances or gifts appears in the Netherlands section of the DGFiP list of treaties consulted. The business succession scheme (bedrijfsopvolgingsregeling) is not detailed here. S53S57

12. France–Netherlands treaty and exchange of information

78. The Franco-Dutch tax treaty was signed in Paris on 16 March 1973 and amended by an amending protocol (avenant) of 7 April 2004, which entered into force on 24 July 2005. The DGFiP publishes a consolidated version incorporating the BEPS multilateral convention (MLI), which entered into force on 1 January 2019 for France and on 1 July 2019 for the Netherlands; this version does not replace the authentic texts. S55S56S57

79. The MLI adds a principal purpose test denying a treaty benefit where obtaining it was one of the principal purposes of an arrangement, unless it is established that granting it is in accordance with the object and purpose of the relevant provisions. It has effect for withholding taxes where the event giving rise to them occurs on or after 1 January 2020 and for other taxes for periods beginning on or after the expiry of a period of six months after 1 July 2019. S55

80. Under Article 10, dividends may be taxed in the State of the distributing company up to 5% where the recipient is a company limited by shares or a limited liability company holding directly at least 25% of the capital throughout a 365-day period that includes the day of payment, a period introduced by the MLI, and up to 15% in other cases. The BOFiP (BOI-INT-CVB-NLD) confirms these two rates for French-source dividends. These limits do not apply where the holding is attributable to a permanent establishment in the State of the company (paragraph 6); paragraphs 3 and 4, on the French tax credit (avoir fiscal) and the French equalisation tax (précompte), are not examined here. S55S56

81. Article 11 allows taxation of interest at source limited to 10%, with exemptions, in particular for loans granted by a banking institution; Article 12 reserves royalties to the State of residence of the recipient. These rules give way where the debt-claim or right is attributable to a permanent establishment, or for royalties to a fixed base, in the other State. Article 13 allocates gains on immovable property and on shares in property-rich companies, assessed over the 365 days preceding the disposal, to the State where the property is situated, and other gains, in principle, to the State of residence of the alienator. S55

82. Article 13(5) reserves to each State the right to tax, in accordance with its legislation, the gain on the disposal of a substantial interest in a company resident in that State realised by an individual resident in the other State, if he or she holds the nationality of the first State without holding that of the other and has been resident there during the five years preceding the disposal. A Dutch national without French nationality who is established in France thus remains taxable in the Netherlands on the disposal of his or her Dutch company for five years. S55

83. Salaries are taxable in the State where the employment is exercised, unless the stay does not exceed 183 days in the fiscal year, the remuneration is paid by an employer who is not resident in that State and it is not borne by a permanent establishment (Article 15). The fees of directors and managers referred to in Article 16 are taxable in the State of the company, unless actual and permanent functions are exercised in a permanent establishment in the other State which bears them. Private pensions are taxable only in the State of residence (Article 18); remuneration and pensions paid by a State in respect of functions of a public nature are taxable in that State (Article 19(1)), except for services rendered in connection with a commercial or industrial activity (paragraph 2). S55

84. Under Article 24, the Netherlands proceeds by proportional reduction of its tax for income taxable in France under the listed Articles, and by a capped credit for dividends, interest, directors' fees and artistes' income. France exempts income taxable in the Netherlands, subject to the effective rate rule (taux effectif), except for income under Articles 8, 10, 11, 16 and 17, which gives entitlement to a tax credit equal to the Dutch tax, capped at the corresponding French tax. S55

85. Article 28 of the treaty provides for exchange of information in older wording. According to the Belastingdienst, more than one hundred States, including all those of the Union, automatically exchange financial information under the Common Reporting Standard (CRS). S55S58

13. Illustrative cases and limits of application

86. Case 1 — a French executive recruited from France settles in Amsterdam in March 2026 with a salary of EUR 120,000. If the 150-kilometre condition is met and the application is filed within four months of the start of the employment, the employer may pay him or her tax-free up to 30% of the salary in 2026, then 27% from 2027 under the enacted Act and the transitional regime; his or her savings in France fall within his or her box 3. S02S21S22S24

87. Case 2 — a Dutch entrepreneur holding all the shares of a BV settles in France. Departure triggers a deemed disposal and a protective assessment of the unrealised gain in box 2, with automatic deferral without interest; a dividend or a sale triggers full or partial payment, and, if he or she does not hold French nationality, the treaty leaves the Netherlands the right to tax the gain realised within five years. S02S27S55

88. Case 3 — a French company has held 30% of a Dutch BV for more than one year. The dividend may be exempt from withholding tax if the holding would qualify for the participation exemption, absent an artificial arrangement; failing that, the treaty limits withholding tax to 5% for a direct holding of at least 25% held for 365 days. The 25.8% conditional withholding tax would in addition require the parent company to be related to the BV, which a 30% holding does not establish by itself (decisive influence, in any event above 50% of the voting rights according to the Belastingdienst), and, France not being a low-tax jurisdiction, the holding to be held with the main purpose, or one of the main purposes, of avoiding tax payable by another person, in the context of an artificial arrangement (Article 2.1(1)(c) of the Wet bronbelasting 2021). S32S35S37S55

89. Case 4 — a resident holds shares on 1 January 2026 which lose value during the year. The deemed benefit applies 6% to investments, but the taxpayer may establish, under Article 5.25, a lower actual return, possibly nil, including unrealised losses, without offsetting against other years. S02S08S11

90. Limits of application: this factsheet does not quantify tax reductions, social security contributions, or the regimes for entrepreneurs, the main residence and pensions. The transitional regime of the 30% ruling, the 30-20-10 sequence and the outcome of the box 3 bill remain to be verified at the date of the transaction. The French consequences, including exit tax and French inheritance tax (droits de succession), are not analysed. S17S19S24S25S55

Sources