The Netherlands State Secretary for Finance has submitted the 2026 Omnibus Tax Bill to Parliament for approval. The Ministry of Finance has published both the bill and its accompanying explanatory memorandum on 25 April 2025.

This legislation introduces various primarily technical, smaller-scale amendments, proposals, and corrections across multiple tax laws.

The key provisions of this legislation are as follows:

Anti-abuse rule 

An anti-abuse rule has been introduced to stop the non-taxability of annuity payments, which effectively closes various existing loopholes. This mainly targets self-managed annuities (arranged with the taxpayer’s own company) rather than third-party annuities, which are taxed at payment by the financial institution.

Corporate Income Tax Act of 1969 amendment

An amendment to the Corporate Income Tax Act of 1969 aims to simplify the process of determining mixed expenses. It establishes that the calculation of non-deductible, mixed expenses will be based on the wages for which wage tax has actually been withheld for the relevant employees.

Documentation for qualifying foreign taxpayers

An amendment suggesting that taxpayers aiming to qualify as a “qualifying foreign taxpayer” be required to submit an income statement only upon the tax inspector’s request.

Tax credit appeals restrictions

For tax credits on low-taxed investment participations, foreign business profits, and benefits from a controlled entity, an amendment states that objections and appeals can only be made against decisions on unused (carried forward) tax credits for the most recent year.

EU SME scheme

The EU SME Scheme introduces an amendment to existing legislation aimed at clarifying information disclosure requirements while preventing issues such as unintentional double reporting or missed reporting of information.