The Netherlands House of Representatives has approved the Fiscal Omnibus Act 2027, introducing changes to R&D tax relief, Pillar Two top-up tax credits, bankruptcy debt forgiveness, pension and annuity taxation, owner-occupied housing, and the historic vehicle tax exemption, with most measures taking effect from 1 January 2027.
The Netherlands House of Representatives passed the Fiscal Omnibus Act 2027 (Fiscale Verzamelwet 2027, the Bill) on 6 October 2026.
The legislation addresses both technical corrections and substantive policy shifts across the country’s tax framework.
The government prepared these amendments to ensure tax law remains current and workable. Several changes include retroactive provisions, most of which take effect on 1 January 2027.
R&D tax credit gets higher wage base
The flat-rate hourly wage for research and development tax relief will increase from EUR 29 to EUR 33 on 1 January 2027. This affects employers who claim the R&D reduction without performing qualifying research activities during the reference year.
Broader tax changes in the bill
The Fiscal Omnibus Act 2027 clarifies several Dutch tax rules, including requiring qualifying domestic top-up taxes (QDMTT) to be considered when calculating credits under the Pillar Two participation credit and foreign permanent establishment exemption regimes.
It also clarifies the corporate tax treatment of debt forgiveness in bankruptcy, confirms the owner-occupied home tax regime for certain value-sharing mortgage products, provides relief for delayed pension and annuity commencements, and updates the motor vehicle tax (MRB) exemption to vehicles acquired before 1 January 1998.
The bill moved through parliament quickly after the government submitted it on 29 April 2026.
The bill now heads to the Senate (upper house of parliament) for approval.
