The Netherlands has submitted the Fiscale Verzamelwet 2027 to parliament, a wide-ranging omnibus tax bill that clarifies how Pillar Two top-up taxes interact with existing credit regimes, tightens the rules on debt forgiveness in bankruptcy, and modernises provisions on owner-occupied dwellings, pensions, and historic vehicles. 

RF Report

The Netherlands government has submitted the Omnibus Tax Bill (Fiscale Verzamelwet 2027) to parliament for approval.

The Bill, together with its explanatory memorandum, was published on 29 April 2026. It sets out the legislative progress of the 2027 Fiscal Omnibus Act, a proposal aimed at revising multiple tax rules and related regulations in the Netherlands.

Some notable provisions in the Fiscal Omnibus Act 2027 include:

Pillar Two / participation credit clarification

This closes a potential ambiguity under the Pillar Two rules. Qualifying domestic top-up taxes (QDMTT) must now explicitly be factored in when calculating the income tax and foreign profit tax that can be credited under the participation credit and the foreign-PE object-exemption regime. This prevents a taxpayer from claiming a credit without accounting for top-up taxes already paid domestically.

Debt forgiveness in bankruptcy

The bill introduces clearer rules on how debt waivers granted during insolvency proceedings are treated for corporate tax purposes, reducing uncertainty for both debtors and creditors in restructuring situations.

Owner-occupied dwelling with value-sharing clause

This responds to the rise of “value-sharing” mortgage products. A home remains a fiscally recognised owner-occupied dwelling (eigenwoningregeling) even where a lender holds a clause that increases interest linearly by at least 100% over up to 10 years tied to property value movements — as long as no other clause cuts the owner’s upside exposure.

Late-starting pensions and annuities

Taxpayers whose pension or annuity begins paying out after the legal start date will not automatically face a punitive tax charge, provided they meet certain conditions. This removes an unintended hardship for those in delayed-commencement situations.

Historic vehicle tax exemption

The cut-off for the motor vehicle tax (MRB) exemption applicable to classic/historic vehicles has been moved to vehicles acquired before 1 January 1998, bringing the threshold up to date.

The Council of State raised no substantive objections to the bill and recommended it be forwarded to parliament without changes; only minor editorial amendments were made before submission.