The follow-up question concerned how the many objections filed under the mass objection procedure would be settled. In the meantime, two collective rulings on objections were published in the Government Gazette on 25 February 2026. Below, we discuss what these rulings entail and what they mean in practice.
Settlement via collective decisions on objection
Because a mass objection designation had been given earlier, the objections were not all dealt with individually. Instead, the Tax Administration has now issued two collective rulings on objections. A distinction was made between:
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Corporate income tax
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Income tax and other tax resources
Corporate tax
For corporate income tax, a collective ruling on objections was published in the Government Gazette (No. 8286) on February 25, 2026. In this ruling, the objections to the higher tax interest rate were upheld.
The Tax Administration will proceed to recalculate the tax interest in the relevant cases. This recalculation will take place within six months of the publication of the collective ruling. This means that taxpayers can expect an amended interest decision or reduction no later than the end of August 2026.
Taxpayers who filed timely objections are not required to take any further action. The adjustment will be made ex officio. No appeal may be lodged against the collective ruling on objection.
Income tax and other tax resources
A collective ruling on objection was also published for income tax and other tax resources in the Government Gazette (No. 8401) on February 25, 2026. In this ruling, the objections were declared unfounded.
The reason is that the Supreme Court ruled that Article 1(a) of the Tax and Recovery Interest Decree (which sets the rate for other tax resources) does not violate the principles of proportionality or equality and is therefore not non-binding. Consequently, no recalculation will take place for these tax resources. The collective ruling on objection is not open to appeal.
Other grounds for objection
The mass objection procedure exclusively concerns the legal question relating to the tax interest rate. If a notice of objection also includes other grounds — for example, objections to (parts of) the assessment itself or to the calculation of the interest — these are not covered by the collective ruling.
In such cases, the objection will be split. The part relating to the tax interest rate will be handled through the collective ruling. Any other disputed points will be assessed separately and individually by the Tax Administration.
This means that, in addition to the collective ruling, an individual decision on objection may follow, but only insofar as the objection concerns issues beyond the mass-designated legal questio n.
What does this mean in practice?
The timeline is thus as follows:
- February 25, 2026: Publication of the collective ruling on objection for corporate income tax and certain related resources (Government Gazette No. 8286) - objections upheld.
- February 25, 2026: Publication of the collective ruling on objection for income tax and other tax resources (Government Gazette No. 8401) - objections declared unfounded.
- Within six months after February 25, 2026 (no later than the end of August 2026): recalculation of tax interest for corporate income tax.
For taxpayers who objected to the regular interest rate for income tax and other tax resources, and whose objections were included in the mass objection procedure, the procedure has now been concluded. For companies that filed timely objections regarding corporate income tax, this means they can expect an amended interest decision in the coming months.
Contact
We would be pleased to assist you with your questions regarding your preliminary and final assessments, the recalculation of the tax interest charged and/or answering your questions regarding this or our previous blogs. Please feel free to contact your Dirkzwager advisor about this.
[1] For completeness, this also covers tax interest for withholding tax, minimum tax, solidarity contribution and profit share. Therefore, when we refer below to tax interest for corporate income tax, unless otherwise indicated, we also mean previous tax resources.
