In 2026, Dutch corporate income tax is levied at:
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19% on taxable profits up to €200,000
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25.8% on profits exceeding €200,000
Taxable profit is based on accounting results adjusted under Dutch tax law. Exemptions such as the participation exemption may apply to qualifying shareholdings. Companies must file annual corporate tax returns and comply with transfer pricing and substance requirements.
Rates, Rules and What Companies Need to Know
Corporate income tax is a central element of doing business in the Netherlands. Whether you operate a Dutch BV, an NV or a permanent establishment of a foreign company, understanding how corporate income tax applies is essential for compliance, financial planning and long-term stability.
The Dutch corporate tax system is structured, transparent and internationally competitive. However, it also requires careful attention to reporting obligations, profit allocation and regulatory compliance.
This guide explains the 2026 corporate income tax framework, including applicable rates, taxable profit determination, participation exemption, loss relief and filing requirements.
Corporate Income Tax Rates in 2026
In 2026, corporate income tax in the Netherlands is levied at 19% on taxable profits up to €200,000 and 25.8% on profits exceeding that amount. Dutch resident companies are taxed on worldwide income, while non-resident companies are taxed on Dutch-source income.
Taxable profit is based on accounting results adjusted under Dutch tax rules. The participation exemption generally allows qualifying dividends and capital gains from subsidiaries to be exempt. Losses can be carried forward indefinitely, subject to limitations.
Who Is Subject to Corporate Income Tax?
Corporate income tax applies to:
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Public limited companies (NV)
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Foundations and associations engaged in commercial activities
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Foreign companies with a permanent establishment in the Netherlands
A company is generally considered Dutch tax resident if it is incorporated under Dutch law or if its effective management takes place in the Netherlands.
Resident companies are taxed on worldwide income. Non-resident companies are taxed only on Dutch-source income.
How Is Taxable Profit Determined?
Taxable profit is based on commercial accounting results, adjusted in accordance with Dutch tax law.
The process typically involves:
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Starting with financial statements prepared under Dutch accounting standards
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Adjusting for tax-specific rules
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Deducting allowable expenses
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Applying relevant exemptions and limitations
Common deductible expenses include operational costs, salary expenses, depreciation and certain interest expenses. However, specific anti-abuse rules may limit the deductibility of interest and related-party payments.
It is important to note that accounting profit and taxable profit are not always identical. Proper tax adjustments are required to ensure compliance.
The Participation Exemption
One of the key features of the Dutch corporate tax system is the participation exemption.
Under this regime, dividends and capital gains derived from qualifying shareholdings are generally exempt from corporate income tax. This prevents economic double taxation within corporate groups.
To qualify, a company typically must:
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Hold at least 5% of the nominal share capital in another entity
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Meet specific activity or asset criteria
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Ensure the subsidiary is not considered a low-taxed passive investment
The participation exemption is a major reason why the Netherlands is frequently used as a holding jurisdiction within international corporate structures.
Loss Relief Rules in 2026
The Dutch corporate income tax regime allows companies to offset losses against profits.
As of 2026:
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Losses can be carried forward indefinitely
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However, only 50% of taxable profit exceeding €1 million may be offset in a given year
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The first €1 million of taxable profit can be fully offset
These rules ensure that companies can benefit from loss relief while maintaining a balanced fiscal framework.
Transfer Pricing and Substance Requirements
Companies engaged in transactions with related parties must comply with Dutch transfer pricing rules. Transactions must reflect arm’s length conditions, meaning they should mirror what independent parties would agree under comparable circumstances.
Multinational groups may be subject to documentation requirements, including local file and master file obligations.
In addition, certain holding and financing companies must meet substance requirements, including sufficient operational presence and decision-making capacity in the Netherlands.
Failure to comply can result in tax adjustments and penalties.
Filing and Compliance Obligations
Companies subject to corporate income tax must:
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File an annual corporate income tax return
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Maintain proper accounting records
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Retain documentation for at least seven years
During the financial year, provisional tax assessments are typically issued. A final assessment is issued after the annual return is submitted and reviewed.
Timely filing and accurate reporting are essential to avoid penalties, interest charges and compliance risks.
Frequently Asked Questions
What is the corporate income tax rate in the Netherlands in 2026?
19% on profits up to €200,000 and 25.8% on profits above that threshold.
Do all Dutch BVs pay corporate income tax?
Yes. Dutch BVs are generally subject to corporate income tax on worldwide profits, unless a specific exemption applies.
Are dividends from subsidiaries taxed?
Dividends from qualifying subsidiaries are typically exempt under the participation exemption.
Can foreign companies be taxed in the Netherlands?
Yes. Foreign companies with a permanent establishment or Dutch-source income may be subject to Dutch corporate income tax.
Can tax losses be carried forward?
Yes. Losses can be carried forward indefinitely, subject to the €1 million and 50% offset limitation.
Key Takeaways
The Dutch corporate income tax system combines competitive rates with a well-defined compliance framework. The two-tier rate structure, participation exemption and structured loss relief provide flexibility for businesses of different sizes.
At the same time, companies must ensure proper documentation, accurate profit allocation and compliance with transfer pricing and substance rules.
Understanding these principles is essential for stable operations and long-term financial planning in the Netherlands.
