Corporate income tax in the Netherlands

Dutch corporate income tax (vennootschapsbelasting) asks for more than filing on time, whether you run a single Dutch company or an international group. Changing EU directives, strict transfer pricing rules and substance requirements all call for technical knowledge and planning ahead.

Our tax specialists handle both the compliance and the advisory side. We help you structure the operation sensibly, file the statutory returns on time and deal with the Dutch Tax and Customs Administration on your behalf.

How we work

Every corporate set-up has its own tax mechanics, from local deductions to cross-border profit allocation. We work in three steps.

• Discovery. We go through your corporate structure, your operating model, your intercompany arrangements and your filing obligations.
• Tax strategy and compliance scan. We analyse your tax position, identify where the risk sits and pinpoint the incentives or exemptions that apply.
• Compliance and advice. We prepare and file the returns, handle questions from the tax authorities and discuss where the position can be improved.

Who this is for

• Dutch entities and group structures that want an accurate annual return and a sound tax position
• Multinationals setting up or running a Dutch holding, operating or IP company
• Foreign businesses with a Dutch subsidiary, branch or permanent establishment
• CFOs and finance directors looking for advice on transfer pricing, restructuring, M&A or intercompany financing
• Fast-growing scale-ups that want to use local incentives such as the innovation box

The points that decide your Dutch tax position

• Fiscal unity. Consolidating profits and losses between a Dutch parent and its subsidiaries, which can reduce the tax due and simplify reporting.
• Participation exemption. Qualifying capital gains and dividends from domestic and foreign subsidiaries exempt from Dutch corporate income tax.
• Innovation box. An effectively reduced rate on profit from qualifying innovative activities and self-developed intellectual property.
• Earnings stripping and interest deduction. Working within the ATAD-based limits when structuring intercompany and external debt.
• Transfer pricing and substance. Arm’s-length pricing on cross-border intercompany transactions, supported by solid documentation and adequate Dutch substance.

What we take on

• Annual return. Translating the commercial financial statements into an accurate tax calculation and handling the formal filing.
• Structuring and restructuring. Domestic and international group structures, cross-border acquisitions and corporate reorganisations.
• Transfer pricing and documentation. Aligning intercompany transactions with Dutch and OECD standards, including master file and local file.
• Advance tax rulings. Obtaining certainty in advance from the Dutch tax authorities on international structures and complex transactions.
• Audits and disputes. Representing your company during tax audits, formal objections and negotiations with the tax authorities.

Need help with your Dutch corporate income tax

Book a short introductory call with our corporate tax specialists to go through your current set-up, the incentives you may qualify for and what full compliance requires. We respond within one working day.