Specific healthcare costs
The scheme for the deduction of expenditure on specific healthcare costs will be abolished from 2028. There will be no transitional provision for a negative personal deduction relating to the deduction of expenditure on specific healthcare costs. This means that any refund or subsequent payment received after 1 January 2028 in respect of healthcare costs previously deducted will no longer result in a negative personal allowance.
Pension capping threshold
Since 1 January 2015, there has been a cap on the income on which a supplementary pension or an annuity can be accrued. This so-called cap is indexed annually. In 2026, the cap will be €137,800. In 2025 and 2026, the cap will not be indexed. It is proposed that the cap should not be indexed in the years 2027 to 2032 inclusive either.
Cost price in the event of a change of registered office
If the effective management of a company is transferred to the Netherlands (transfer of registered office), a significant shareholder residing abroad becomes liable for income tax abroad. As a result, income tax is payable in Box 2 in the Netherlands on both regular benefits and capital gains.
On the basis of the current wording of the law, it can be argued that the acquisition cost should be determined as the (historical) consideration paid upon acquisition of the substantial interest. To prevent this, it is proposed that, in the event of a change of registered office, the acquisition price should be set at the market value of the substantial interest at that time. As a result, only any increase or decrease in value occurring after the change of registered office will be included in income under box 2.
Inherited allowance and notional standard allowance
In the case of an inherited substantial interest, a scheme may be utilised, subject to certain conditions, whereby regular benefits received within 24 months of death are not immediately taxed in box 2. This relief may have undesirable consequences in the case of a notional regular benefit under the Act on Excessive Borrowing from One’s Own Company. It is proposed that the relief for an inherited substantial interest should not apply to this notional benefit. Furthermore, the measure prevents double taxation. Without this exclusion, the maximum amount of €500,000 cannot be increased, meaning that, if the debt remains unchanged, a notional regular benefit would arise again in a subsequent year.