17/September/2025

On 16 September 2025, the Dutch caretaker government presented the Tax Plan 2026. Four key takeaways for (real estate) investors, funds and managers:

• Funds for Joint Account (FGRs)
  To mitigate unintended consequences of the new classification rules, a transitional regime is proposed. Funds that were tax transparent before 2025 may opt to remain transparent until 2028. This offers breathing room while the broader FGR regime is under review.
• Lucrative interest regime
  The lucratief belang rules will be tightened. Box 2 taxation of lucrative interests will increase to an effective rate of up to 36%, and transfers from box 1 to box 2 will no longer allow taxpayers to step up the cost price to fair market value.
• Real estate transfer tax (RETT)
  The RETT rate for investors in residential property will fall from 10.4% to 8% as of 1 January 2026. The 2% rate for owner-occupied homes, the 0% rate for first-time buyers, and the 10.4% rate for non-residential property investors remain.
• New VAT revision rules for real estate services
  As announced on the previous Budget Day, a five-year VAT revision period will be introduced as of 1 January 2026 for certain services pertaining to real estate, including renovations, repairs and maintenance, to the extent these services cost at least EUR 30,000. If property use changes (e.g. from VAT-taxed to VAT-exempt), part of the earlier deducted VAT becomes payable.