Spring 2025 has got off to a cautious start. We have already enjoyed some beautiful sunny days. Meanwhile, the Cabinet has also announced the annual spring note published. What you think of all these measures is a political question, from which we stay away. We confine ourselves to briefly touching on some of the fiscal measures in the Spring 2025 policy paper, noting that the political yo-yoing does make it difficult for us to provide you with solid consistent advice that will last for several years.
Box 3
Immediately striking are the plans with Box 3. This is the box in which income from savings and investments is taxed with income tax. The previously suggested increase in the flat rate of return against which other assets are taxed will be introduced from the 2026 tax year. Based on the current flat rate of return of 5.88%, the flat rate of return in 2026 would go up to 7.66% (a 1.78%-point increase). The only justification for this increase is that money is needed to cover other measures.
Another change regarding box 3 is the reduction of the tax-free assets from (per tax partner) €57,804 in 2025 to €51,396.
This higher box 3 levy should cover the gap created when people start relying on the Box 3 Counter Evidence Act. See our article Box 3 rebuttal scheme.
Box 3 rate remains unchanged: 36%.
Co-work and cessation deductions
For income tax entrepreneurs, the co-employment deduction will be abolished. This deduction can be claimed by an entrepreneur who meets the hour criterion and whose tax partner contributes at least 525 hours to the business. However, the possibility of granting the tax partner a bonus for cooperating remains.
Entrepreneurs who cease their business may deduct the cessation deduction from the cessation profit. The cessation deduction may be applied by every entrepreneur once in his or her lifetime and currently amounts to €3,630. This amount will be reduced to €908 from 2027 and abolished from 2030.
VAT
The reversal of the (not yet implemented) increase in the VAT rate on culture, media and sports had already been announced and will be made final in the Spring Memorandum. The coverage needed for it (a sloppy €1.3 billion) will be found in not fully implementing the inflation adjustment in income tax rates before 2026.
Lodging does move from the reduced VAT rate of 9% to the general rate of 21% with effect from 1 January 2026. Bookings made in 2025 for overnight stays in 2026 should already take into account the rate of 21%.
Notable tax structures
Five constructions are added to the list of notable tax constructions compiled last year.
- Fruit juices with a “touch of dairy”, avoiding the consumption tax on non-alcoholic beverages. It is proposed that the exemption from that tax should only apply to pure dairy drinks, such as skimmed, semi-skimmed and whole milk.
- In view of the death of one of the spouses, modify the entitlement to the assets of the matrimonial community of property to avoid and/or defer levying of inheritance tax and income tax. It is proposed to levy inheritance or gift tax when a beneficiary of a matrimonial community of property acquires more than 50% of that community.
- Untaxed access to annuity capital (this construction is not explained in the annex to the spring note).
- Partnerships entrepreneur with own BV: to enjoy the entrepreneurial facilities (SME profit exemption and self-employed deduction) on the DGA's “salary” transformed into profit. Considered is the denial of these facilities when the BV is part of the partnership or general partnership in which its director-major shareholder also participates.
- Lucrative interest scheme, which plays out particularly in private equity structures.