DUTCH SPRING TAX MEMORANDUM 2022

03/06/2022

The Dutch Ministry of Finance has published its Spring Memorandum for 2022 on 20 May 2022. We have set out all the planned tax measures[1].

 

• The bracket limit in the Dutch Corporate Income Tax, in which taxpayers pay 15% tax, will be reduced from € 395,000 to € 200,000 as of 2023. This results in that taxpayers will pay the 25,8% rate over the excess of € 200.000 earlier.
• The coalition agreement's step-by-step increase in the tax-free assets in the Personal Income Tax (“PIT”) Box 3 from € 50,650 to ultimately around € 80,000 will not be implemented anymore.
• In Box 2 of the PIT regarding income from substantial interests, a two bracket system will be introduced as of 2024 with a basic rate of 26% for the first € 67,000 of income per person and a rate of 29.5% for the excess.
• The efficiency margin in the customary wage scheme will be reduced from 25% to 15%. The effect of the lowering of the efficiency margin is that the salary for the director and major shareholder (DGA) may be set 25 percent lower than the salary that is normal for the level and duration of the DGA's employment. This margin will be reduced to 15 percent, as a result of which the director and major shareholder will pay more tax in Box 1 of the PIT.
• As of 2025, the income from Box 2 and Box 3 (the collective income) will be taken into account for the reduction of the general tax credit in addition to Box 1 income.
• The 30% rule will be limited to the 'Balkenende norm' (2022: € 216,000). There will be a transitional arrangement with a three-year phase-in period.
• The general rate of (real estate) transfer tax will be increased from 9% to 10.1%.
• The Fiscal Old-Age Reserve (for PIT-entrepreneurs) will be abolished as of January 1, 2023. The FOR already accrued can still be phased out on the basis of the current rules;
• The untaxed travel allowance will be increased in 2023 instead of 2024.