For Dutch tax purposes, 2026 will be a year in which the tax authorities will not surprise you too much. Due to collapse of the Dutch coalition government in 2025 and the subsequent elections, the government is acting in a caretaker capacity. Therefore, major tax reforms will remain on hold for the time being. 

At this stage, a number of political parties is discussing the formation of a government. As soon as there will be a new government coalition, more changes may be expected, although this will take some time. However, there are still a few changes for 2026 that may be relevant. In particular, we will elaborate on the mutual fund in connection with the update of the fund decision.

Status quo
The Dutch corporate income tax purposes, the rates and regulations will remain unchanged in 2026, which means that companies can prepare for a stable tax environment for that year.

The same applies in broad terms also for the dividend withholding tax. 

For personal income tax purposes, there are minor changes to rates and thresholds. The planned increase in taxation in box 3 for 2026 will no longer take place. The government wanted to increase the assumed return for other assets in box 3 from 6% to 7.78% and reduce the tax-free allowance from €57.684 to €51.396. The tax-free allowance will instead be increased to €59.357, following the inflation.

For value added tax purposes, one interesting development is the introduction as per 2026 of a five-year review period that will apply to investment services. This means that the VAT deduction for investment services will be monitored for four years after the year of commissioning. During the review period, it must be checked each year whether the ratio between taxable and exempt use is still the same as in the year in which the use of the investment service started. If this is not the case and the difference is more than 10%, the VAT deduction must be reviewed. A threshold of EUR 30,000 per service applies to strike a balance between the intended effect of the measure and the administrative burden. 

Finally, for the tax treatment of so-called ‘lucrative interests’ (i.e. the Dutch carried interest taxation rules), a form of remuneration which was common for PE managers, it was proposed by the government to increase the effective tax rate to 36% for indirectly held interests. However, this measure has been postponed and a decision should be taken by the new government.

FGR
On 3 December 2025, a new resolution issued by the Dutch State Secretary of Finance came into effect, the 2025 fund resolution. This is an update of an earlier resolution. With the change in the definition of fund for joint account (in Dutch: fonds voor gemene rekening, FGR) as of 1 January 2025 and the subsequent discussions, there were good reasons to amend the resolution. 

Funds that meet the definition of an FGR are in principle not tax transparent and may become independently taxable. However, there is still an exception to this independent tax liability, namely for the so-called purchase funds.

Purchase funds are investment funds in which the certificates of participation are non-transferable. The certificates of participation are considered non-transferable if they can only be sold to the fund itself. 

However, it is possible for the unit holder to sell a certificate to the fund, and for the fund to then immediately reissue that certificate to a third party/

Funds that have amended their articles of association to those of a purchase fund before 1 January 2026, can make use of transitional law. This way, the fund can avoid being liable for tax for a short period of time, before possibly becoming transparent again. This transitional law will apply until the introduction of a possible new definition of the FGR, but no later than 1 January 2028.

Furthermore, an FGR is not included as a legal form in the Civil Code or the Commercial Code. This may result in an FGR taking the form of, for example, a limited partnership (CV). If a fund meets the definition of both an FGR and a transparent fund, the qualification as an FGR takes precedence over the qualification as a transparent entity. It is also possible for a fund to participate in a CV. In that case, this does not necessarily mean that the fund is operating a business, and it is still possible for the fund to meet the investment conditions to qualify as an FGR, even if the CV is running an enterprise.

Crypto
As from 1 January 2026, crypto providers will be required to collect, verify, and report their users' transaction data to the tax authorities of EU member states. This applies not only to the purchase and sale of crypto, but also to cases where crypto has been used for a purchase. The aim is to give tax authorities more insight into crypto assets, as these are not always declared.

Please do not hesitate to contact us if you have any questions or would like to discuss the consequences for your situation.

Regarding tax advice or questions about this blog, please contact Peter van Dijk (vandijk@dayonelegal.nl)