As we approach the end of the year, it is essential to consider the fiscal, legal, and administrative changes that will affect your business operations, private wealth position, and employment policies in 2025 and 2026. This document provides an extended overview of the most relevant developments, enabling you to anticipate changes in good time and to take informed, strategic action.
Entrepreneurs – Key Tax and Compliance Considerations
For entrepreneurs who utilised the accelerated depreciation scheme in 2023, it is critical that the related assets are brought into use no later than 1 January 2026. Missing this deadline may result in the loss of the additional depreciation benefit. Furthermore, the timing of investments continues to play a significant role. By spreading investments across 2025 and 2026, you may optimise your Small-Scale Investment Allowance (KIA).
From 2025, the Energy Investment Allowance (EIA) is subject to a new consolidated maximum of €151 million per taxpayer per year, regardless of whether investments are made individually or through partnerships. This measure was introduced to prevent over-application of the EIA across multiple structures.
Entrepreneurs owning property used for business purposes may, in specific transitional cases, benefit from one final year of depreciation under the former rules in 2025. This applies only if the property has not yet been depreciated for three full financial years and was already part of the business or result assets before 2024.
If you have formed a reinvestment reserve (HIR) in 2021, this reserve must be used this year to avoid being added to your taxable profit. Additionally, extensive changes will be introduced to the VAT revision scheme in 2026. Renovation and improvement services that exceed €30,000 will fall under a multi-year revision obligation, requiring real estate entrepreneurs to adjust their bookkeeping and monitoring systems accordingly.
The potential impact of disinvestments should also be considered. The sale or transfer of an asset within five years of investment may lead to a disinvestment recapture. A careful review of the investment date is therefore essential before taking action.
If you still have losses from 2016, note that these will expire after 31 December 2025. Advancing revenue, realising hidden reserves, or deferring expenses could allow you to utilise these losses before they lapse.
For the hospitality sector, the VAT rate for accommodation services will increase from 9% to 21% on 1 January 2026. This change affects pricing, booking systems, and package arrangements. Bookings made in 2025 for stays in 2026 will already be subject to the 21% rate.
The Dutch Tax Administration has intensified its enforcement against false self-employment. Although the final legislative framework (Vbar or the Self-Employment Act) is still pending, businesses should critically review agreements, work processes, and the positioning of contractors.
In addition, a statutory ban on cash payments above €3,000 for professional goods traders will take effect in 2026.
Finally, further amendments will be made to the Business Succession Facilities (BOR and DSR) per 2026. These include the easing of certain ownership and continuation requirements, as well as tightened rules to counter avoidance structures and a revised definition of preferential shares.
Directors–Major Shareholders (DGAs) – Strategic Fiscal Planning
For DGAs, the excessive borrowing rules remain a priority. Loans from your own company will again be assessed at year-end 2025. Any amount exceeding €500,000 may trigger box 2 taxation, unless the balance is reduced through repayment, refinancing or dividend distribution. Since dividend distributions also affect the reduction of general tax credits from 2025 onwards, a precise calculation is essential.
Box-2 losses from 2019 will lapse after 2025 if not offset. By arranging dividend distributions or other profit transfers in 2025, you may still be able to utilise these losses. If your substantial shareholding has ceased, an expired box-2 loss may under certain conditions be converted into a tax credit in box 1, provided this occurs within the statutory period.
To avoid 9% corporate tax interest, it may be prudent to request an additional provisional corporate income tax assessment if profits exceed earlier expectations.
Amendments to the lucrative-interest regime, relevant to private equity structures and certain employee participation schemes, have been postponed until 2028. This provides two additional years during which income can still be taxed under the current, more favourable box-2 rates.
For funds for joint account (FGRs) that opted to become redemption funds as of 2025, it is crucial to verify that all conditions are met by the end of this year to maintain the intended classification.
Employers and Employees – Payroll, Mobility and HR Implications
The additional tax liability (bijtelling) for new electric company cars remains relatively favourable in the coming years, starting at 17% over the first €30,000 of catalogue value. Existing 60-month periods for earlier vehicles continue unchanged, although increases will apply once these periods expire.
Within the Work-Related Costs Scheme (WKR), employers should carefully monitor their remaining discretionary space for 2025 to avoid unexpected 80% final levy. For larger groups, the optional ‘group scheme’ may result in a lower collective tax burden. Proper designation of reimbursements remains crucial, as the tax authority assumes designation only for benefits granted within the same year.
Projects funded under the MDIEU-scheme must be completed by 31 December 2025. Applications for R&D payroll tax reductions (WBSO) must be submitted before 20 December 2025 for work starting 1 January 2026.
The extraterritorial expenses scheme (ETK) will be further tightened from 2026, limiting the scope of tax-free reimbursements. The 30% ruling will also be adjusted in 2027, including revised salary thresholds and a gradual reduction of the applicable percentage.
The Labour Cost Allowance (LKV) for older workers will be fully abolished from 2026 for new employment relationships, while the LKV for workers covered by the Jobs Agreement (banenafspraak) will be significantly simplified and extended for unlimited duration.
Lastly, it is advisable to thoroughly review the 2026 Whk premium decisions, as inaccuracies occur frequently and can be corrected only through timely objection.
All Taxpayers – Private Wealth, Property and Box 3 Developments
Major changes in box 3 (wealth tax) will apply from 2026. The private use of real estate will be included based on an economic rental value equalling 5.06% of the WOZ value. Until 2028, taxpayers may provide counter-evidence if the actual return is demonstrably lower than the notional return.
The deduction room for annuity premiums has been significantly expanded. However, only contributions paid in 2025 can be deducted in the 2025 tax return, making timely payments essential.
The tax-free allowance in box 3 will increase to €59,357 per person in 2026. The notional return for “other assets” will increase moderately to 6%, instead of the previously proposed 7.78%. These changes make it worthwhile to reassess your box-3 position, potentially through strategic repayments, asset reallocation, or additional pension funding.
Cryptocurrency holdings must be disclosed before 2026. Starting next year, cryptocurrency platforms will automatically report holdings and transactions to the Dutch Tax Administration—making voluntary correction virtually impossible thereafter.
Taxpayers still eligible for income averaging (middeling) may apply for the final time in respect of income fluctuations up to and including 2024.
From 2026, several property-related measures will change, including adjustments to the vacancy value ratio for let residential properties, updated rules for service charges, a reduced transfer tax rate for box-3 property acquisitions, and amended conditions for the starter’s exemption. In some cases, postponing a property purchase until 2026 may be financially advantageous.
We Are Here to Support Your Financial Decision-Making
We are here to help you analyse how these developments affect your specific circumstances. As a full-service accounting and advisory firm, we support clients with proactive tax optimisation, payroll compliance, financial structuring, real-time administration, and year-end planning. Our goal is to provide clarity, reduce complexity, and ensure that your organisation remains compliant while taking advantage of available opportunities.
If you would like us to assess which measures are most beneficial for you or your business, we are happy to schedule a personal consultation.
You can reach us at +31 (0)88 011 40 00, via info@practical.nl, or by scheduling an appointment directly through www.practical.nl. We look forward to assisting you.
