The Decree provides guidance on calculating the VAT taxable amount, offering clarification on the treatment of fuel or charging cards and the transfer of negative interest by service providers.

The Netherlands Ministry of Finance published Decree 2025-23004 of 29 September 2025, in the Official Gazette No. 33827 on 6 October 2025.

Decree 2025-23004 replaces Decree No. BLKB 2018/84956 of 29 June 2018 and applies from 7 October 2025.

Decree 2025-23004 provides guidance on calculating the VAT taxable amount, offering clarification on the treatment of fuel or charging cards and the transfer of negative interest by service providers.

The key measures are:

Taxable VAT amount

The VAT taxable amount refers to the total charge for goods or services, excluding VAT, and requires a clear connection to the supply or service provided. However, some payments do not have this direct link. For example, deposits or fines paid by a property buyer under a purchase agreement, which the seller can retain if the buyer fails to meet their obligations, are not directly linked. Similarly, call-out fees charged by a supplier or service provider when a customer is not home to receive the agreed-upon goods or services also lack this connection.

Provision of fuel and electricity via fuel or charging cards

The Court of Justice of the European Union (Case C-60/23) has ruled that when a card operator facilitates the purchase of fuel or electricity for motor vehicles, these transactions can qualify as supplies of goods under Article 14(2)(c) of Council Directive 2006/112/EC. In this arrangement, the card operator pays the supplier for the fuel or electricity and then passes these costs on to the cardholder.

For this to be treated as a supply of goods, the billing process must show that the cardholder acts as a commission agent. This is established if the supplier invoices the card operator, and the card operator, in turn, invoices the cardholder. The updated decree confirms that this VAT treatment remains valid even if multiple suppliers are involved in the chain of transactions.

Transfer of negative interest by a service provider

If a bank charges negative interest on a security deposit, the service provider can pass this cost to the deposit holder. The decree specifies that this does not count as part of the compensation.