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ARTICLE · 18 SEPTEMBER 2026

Dutch Tax Plan 2027

A&O Shearman
A&O Shearman
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The Dutch government has released its comprehensive tax plan for 2027, introducing significant changes across corporate income tax, dividend withholding tax, Pillar 2 implementation, employment taxation, and real estate transfer tax. Key measures include modifications to the participation exemption regime for hedging instruments, implementation of the OECD Side-by-Side Safe Harbour package for US-headed multinational groups, and new stock option schemes for startups and scale-ups designed to strengthen the

NetherlandsTax

On September 15, 2026, Dutch Budget Day (Prinsjesdag), the Dutch government released its tax plan for 2027 and some other tax related legislative proposals. In this publication, we will highlight the most important topics and take the opportunity to discuss some other notable Dutch tax developments for 2027 and beyond.

1. Introduction

2. Corporate income tax​
2.1 The participation exemption no longer applies to priced-in components
of hedging instruments for participations in foreign currencies
2.2 Opting out of the Dutch participation exemption on foreign exchange
results on hedging instruments after an earlier opt-in
2.3 The statutory presumption of abuse in demergers and business
mergers is no longer included in the Dutch Corporate Income Tax Act

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