Spring Memorandum 2025: new tax measures expected

The Dutch coalition government recently agreed on an update to the budget for 2025 and later years. The final 2026 budget will officially be announced for the occasion of Budget Day on 16 September next. The proposed measures introduce several significant tax changes impacting individuals, startups, scale-ups and corporations. This update provides an overview of the most relevant fiscal adjustments.
 
Tax incentive for employee stock option plans for innovative start-ups and scale-ups
New tax rules will be introduced to promote employee participation in innovative start-ups and scale-ups. Under this measure, employees will benefit from a reduced personal income tax base on stock options. More specifically, only 65% of the capital gain will be subject to tax resulting in an effective tax rate of approximately 32%. Additionally, taxation will be deferred until the moment the shares are actually sold. The new rules are expected to enter into force on 1 January 2027.
 
Changes in Box 3 rules
The Dutch wealth tax (Box 3) taxation rules remain complex and subject to continuous legislative changes and case law. The government previously announced the transition to a system based on actual returns instead of deemed returns. The implementation of this reform has been postponed until 1 January 2028. In the meantime, the government proposes to increase tax revenue by taking the following measures:

1. The tax-free allowance (in Dutch: heffingsvrij vermogen) will be reduced from EUR 57,684 to EUR 51,396 in both 2026 and 2027. For tax partners, the combined tax free allowance will be reduced from EUR 115,368 to EUR 102,792.
2. Box 3 is levied on three categories based on a deemed return on assets minus liabilities at a rate of 36% in the years 2025 and 2026. The deemed return on ‘other assets’, such as real estate and shares not held in a substantial interest, will be increased with 1.78 percentage points to 7.78% as of 1 January 2026. Based on case law, if the actual return is lower than the deemed return, it is possible to opt for box 3 taxation based on the actual return.