Developments Of The Corporate Tax Loss Relief Rules

A recently published Royal Decree formalised the entry into force date of the revised Dutch corporate income tax loss relief rules at 1 January 2022. Following these rules, tax loss can be carried back one year and carried forward indefinitely subject to a quantitative restriction. It is recommended to analyse the impact of these changes for your business, both from a taxation and accounting perspective.

Amendments to the corporate tax loss relief rules

As of 1 January 2022, the Dutch loss relief rules in the corporate income tax act will be amended. Current loss relief rules allow Dutch taxpayers to offset loss against profits of the previous year (i.e. carry back) and the six following years (i.e. carry forward). No quantitative restriction applies. As of 1 January 2022, loss can still be carried back one year but carried forward indefinitely. However, a quantitative restriction will be introduced, as a consequence of which the annual loss compensation will be