Every third Tuesday of September the same ritual plays out in The Hague: the budget is presented, the tax plan lands with it, and within hours the summaries start circulating. Most of them run to dozens of pages and treat a change to the excise duty on beer with the same weight as a change to your box 2 position. If you run a business, own one through a holding company, or live and work across borders, you do not need all of it. You need to know which measures actually touch you and, just as importantly, which ones reward acting before 1 January and which ones reward waiting.

The 2027 Tax Plan is not a year of grand reform. It is a year of trimming: several long-standing allowances for the self-employed are being wound down, a handful of reliefs are being frozen rather than indexed, and a number of court rulings are being written into law. But underneath the trimming sit a few genuinely useful changes, from a quadrupled innovation box lump sum to a step-up for shareholders of companies that move to the Netherlands. In this article we set out the measures that matter most for entrepreneurs, owner-directors and internationally mobile taxpayers, and where the timing makes a difference. Not an exhaustive list of every proposal, but a practical overview of the points that deserve a place on your agenda before the year ends.

Table of contents

1. Rates and credits: a little more tax at the top, a little less at the bottom

2. Innovation box: the lump sum quadruples

3. The self-employed: three allowances head for the exit

4. Share options at start-ups and scale-ups: tax at sale, on 65%

5. Mergers and demergers: the three-year presumption disappears

6. Borrowing from your own company: a fix for inherited debt

7. Real estate: transfer tax on second homes drops to 7%

8. Employers: mileage, pensions and the work-related costs scheme

9. International: a step-up on arrival, and the 30% ruling becomes 27%

10. What to do before 1 January, and what to leave until after

1. Rates and credits: a little more tax at the top, a little less at the bottom

The box 1 rates for people below state pension age move in familiar small steps. The first bracket is expected to run to EUR 39,247 at 36.23%, the second to EUR 78,426 at 38.16%, and everything above that stays at 49.50%. Compared with 2026 that is roughly half a percentage point more in the first two brackets, partly offset by a slightly longer first bracket. For most employees and owner-directors on a customary salary the net effect is modest.

The credits move in the opposite direction. The general tax credit rises to a maximum of EUR 3,154 and the employed person’s credit to EUR 5,929, both up from 2026. The income-dependent combination credit for working parents goes the other way: it drops to EUR 2,918 in 2027 and is now on a published path to complete abolition in 2035, so families that rely on it should stop treating it as a permanent feature.

One earlier decision also lands this year. The self-employed deduction falls again, from EUR 1,200 to EUR 900. On its own that is a small number. Read together with section 3, it is part of a clear direction: the fiscal distance between a sole trader and an employee is being closed, one allowance at a time.

2. Innovation box: the lump sum quadruples

The innovation box taxes profit from self-developed intangible assets at 9% instead of the normal corporate rate. For smaller companies the barrier has never been the rate, it has been the paperwork: allocating profit to a specific asset is expensive, and for a business with a few tens of thousands of euros in qualifying profit the exercise rarely paid for itself. The lump sum alternative solved that in principle but was capped so low that few bothered.

That changes. Under the proposal a company that opts for the lump sum may treat 25% of its profit as innovation profit, and the maximum amount that can enter the box this way rises from EUR 25,000 to EUR 100,000 per year per taxpayer. The lump sum applies in the year the asset comes into existence and the two following years. For a software company, a product developer or an engineering firm with a modest patent portfolio, this turns a theoretical relief into a real one.

Two things to keep in mind. The lump sum replaces the normal allocation, so a company with large innovation profits may still be better off doing the full calculation. And if your group is large enough to fall under the global minimum tax, be aware that the innovation box is not covered by the new safe harbour for incentive regimes, because it follows income rather than investment. In that setting the 9% rate can trigger top-up tax elsewhere.

3. The self-employed: three allowances head for the exit

The starters’ allowance is effectively gone. It drops from EUR 2,123 to a symbolic EUR 10 on 1 January 2027 and is abolished altogether in 2028, with no transitional protection for people who started their business before 2027. The accelerated depreciation option for starters ends in 2028 as well, and the starters’ allowance for the partially disabled follows in 2029.

Two more allowances are being used to pay for something else. The co-working partner deduction, for entrepreneurs whose partner works in the business without pay, and the discontinuation allowance, which shelters part of the profit when you stop, are both cut by roughly three quarters first and abolished three years later. The discontinuation allowance falls from a maximum of EUR 3,630 to EUR 908. If you were counting on it for a planned exit, it is worth checking whether the timing of that exit still makes sense.

Taken together with the shrinking self-employed deduction, the message is unambiguous. The remaining tax advantages of operating as a sole trader are being phased out, and for a growing business the comparison with a private limited company deserves a fresh look rather than an inherited assumption.

4. Share options at start-ups and scale-ups: tax at sale, on 65%

This is the measure the previous three are funding, and for founders and their early employees it is a significant one. Today an employee who receives share options is generally taxed when the shares become tradeable, or at exercise if they choose, on the full value of the benefit. That produces the well-known problem of a tax bill on paper wealth before any cash has been received.

For employees of qualifying start-ups and scale-ups the proposal moves the taxable moment to the actual sale of the shares, and counts only 65% of the benefit as wages. In practice that means the tax follows the cash, and at a materially lower effective rate. The scheme is intended to apply from 2027 and comes with conditions, including as a rule a minimum of two years between grant and sale.

The transitional rule is unusually generous and worth flagging to anyone who granted options recently. Options granted on or after 17 April 2025 that have not yet been taxed by the end of 2026 can be brought under the new scheme, provided the required ruling is applied for by 31 December 2027. If you run a start-up with an option plan, that is a date for the calendar.

5. Mergers and demergers: the three-year presumption disappears

A business merger or demerger can be carried out without an immediate tax settlement, as long as the reorganisation is not mainly aimed at avoiding or deferring tax. Until now the law added a presumption: if you sold one of the companies involved to an independent buyer within three years, you had to prove yourself that there were sound business reasons. The Supreme Court held that this reversal of the burden of proof is incompatible with European law, and the presumption is now being removed. Going forward the inspector has to produce at least a beginning of evidence before the facility can be challenged.

That is good news on the substance, but it comes with a practical loss. Because the presumption no longer exists, the Tax Administration will also no longer give advance certainty specifically about a sale within three years. The inspector can still question a reorganisation on ordinary grounds. So the burden shifts, but the need for a well-documented business rationale does not go away, and if anything a solid file becomes more important precisely because there is no longer a formal ruling to hide behind.

6. Borrowing from your own company: a fix for inherited debt

Owner-directors who owe their own company more than EUR 500,000 are deemed to receive a dividend for the excess. That rule has been in place for a few years. What the current text did not handle well is death. When shares are inherited, regular income from those shares received within 24 months after death can under conditions stay outside box 2, with a corresponding reduction of the acquisition price. Applied to the deemed dividend on excess debt, that produced an odd result: the exclusion applied, but the EUR 500,000 threshold did not move up with it, so the following year the same debt triggered tax again.

The proposal removes that overlap. For estates that include both shares and a substantial debt to the company, the practical consequence is that box 2 tax on the excess can be due straight away rather than being pushed around between years. Anyone with a large current account debt to their holding company should look at this in the context of their estate planning, not only their annual return.

7. Real estate: transfer tax on second homes drops to 7%

The general rate of transfer tax for homes that the buyer will not use as a main residence falls from 8% to 7%. That covers rental property, second homes and holiday homes, and the stated aim is to make investing in rental housing more attractive again. The 10.4% rate for non-residential property, the 2% rate for owner-occupiers and the starters’ exemption all stay as they are.

The timing point is obvious but easy to miss in the excitement of a purchase. If you are planning to acquire a property that will not be your main residence and the transfer can reasonably take place after 1 January 2027, the difference is a full percentage point of the purchase price. On a EUR 600,000 apartment that is EUR 6,000 for signing a few weeks later.

Two housing measures aimed at housing corporations round out this chapter: a new transfer tax exemption for transfers between corporations of property used for services of general economic interest, and an exemption for corporations from the general interest deduction limitation in corporate tax. Both are sector-specific and will not affect most private investors.

8. Employers: mileage, pensions and the work-related costs scheme

The tax-free mileage allowance rises from EUR 0.23 to EUR 0.25 per kilometre, and does so with retroactive effect from 1 January 2026, formalising an earlier policy decision. Employers are not obliged to pay it, and if you want to apply the increase for the whole of 2026 you need to agree that with your staff. The same EUR 0.25 applies to the deductible travel costs of entrepreneurs and to a few forfaits in the personal deductions.

The work-related costs scheme gets slightly more room: the free space over the first EUR 400,000 of the wage bill goes from 2% to 2.16%, with 1.18% above that unchanged. Against that, the targeted exemption for staff discounts on the company’s own products, up to 20% and EUR 500 per employee per year, is abolished. Those discounts can still be given, but they will now consume free space, and many employers will find that the two changes roughly cancel each other out.

The quietest measure in this chapter may end up being the most expensive over time. The salary cap for tax-facilitated pension accrual, EUR 137,800 in 2026, will not be indexed from 2027 up to and including 2032. Over six years of wage growth that pulls a steadily larger group of higher earners above the cap, and above it no second-pillar pension or third-pillar annuity can be built with tax relief. For owner-directors who fund their own pension the arithmetic changes accordingly.

9. International: a step-up on arrival, and the 30% ruling becomes 27%

The most welcome international measure fixes a long-standing unfairness. When a foreign company moves its place of effective management to the Netherlands, a foreign-resident shareholder with a substantial interest becomes liable to Dutch box 2 tax on that holding. Until now the acquisition price for Dutch purposes was the historical cost, which meant the Netherlands could tax value growth that arose long before it had any taxing right. Under the proposal the acquisition price is set at the fair market value at the moment of the move, so only the increase after that date is taxed here. The step-up does not apply if the shareholder was already a Dutch non-resident taxpayer for that holding, and separate rules are announced for returning residents. A defensible valuation at the date of migration becomes essential, because without one you cannot later show which part of a gain falls outside Dutch tax.

For internationally recruited staff, previously enacted changes now bite. From 2027 the 30% ruling becomes a 27% ruling and the salary thresholds rise. Employees who came in by the end of 2023 keep 30% and the old indexed thresholds. Those who arrived in 2024 move to 27% but keep the old salary norm. The transitional protection for the partial non-resident status, which allowed expats to keep foreign assets outside box 3, also runs out at the end of 2026. If you employ, or are, someone on the ruling, 2027 looks different from 2026 and the payroll should reflect that from the first month.

Three further items for groups and investors. First, the global minimum tax gets four OECD-agreed safe harbours that set the top-up tax for a country at nil when the conditions are met, including a simplified calculation and a safe harbour for groups with a parent in a country with an equivalent regime, with the United States clearly in mind. Parts of this apply retroactively to the end of 2025. Second, investors who hold Dutch shares through a foreign investment fund get a statutory right to a refund of Dutch dividend tax for tax withheld from 2027, following a 2024 Supreme Court ruling, with a five-year window to claim and three years for companies. Third, for companies that hedge the currency risk on a foreign participation and have the result covered by the participation exemption, the part of the result that was already priced into the hedge through the interest differential becomes taxable from financial years starting in 2027, with old law continuing until the end of 2027 for hedges approved or applied for before 15 September 2026.

10. What to do before 1 January, and what to leave until after

A tax plan is a list of proposals until parliament has voted, and details can still move in the coming months. That said, the direction is clear enough to act on, and the calendar sorts itself into three groups.

Act before the year ends if you are planning a business merger or demerger and want to make use of a ruling on a possible sale within three years, because that option disappears. Check whether existing hedges on foreign participations were approved or applied for before 15 September, since that determines whether you keep the old treatment through 2027. If you are on the 30% ruling, or employ people who are, work out what 27% and the higher salary norm mean for 2027 payslips now, and remember that the partial non-resident status ends. And if you still have deductible healthcare costs that can be planned, 2027 is the last year for that deduction.

Wait until after 1 January if you are buying a home you will not live in, because transfer tax drops a point. Consider the same for energy-saving investments on the energy list, where the deduction rises from 40% to 45.5% for commitments entered into in 2027. And if you have a start-up option plan, do nothing rash: options granted since 17 April 2025 that are still untaxed at the end of 2026 can move into the new regime, provided the ruling is requested in time.

Finally, two structural questions rather than deadlines. If you operate as a sole trader with a growing profit, the steady removal of allowances makes the comparison with a private limited company worth redoing on 2027 numbers. And if you are a foreign shareholder considering moving a company’s management to the Netherlands, the new step-up removes what used to be the biggest objection, provided you document the value at the date of the move. Both are conversations we are happy to have with you, ideally before the calendar turns rather than after.