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Key highlights from the Tax Plan 2024

On Tuesday, September 19, 2023 (Budget Day), the outgoing Dutch Minister of Finance revealed the Tax Plan 2024 in which several tax measures were announced. You will find our publication Tax Plan 2024 Special attached, in which we outlined the most important measures from an international perspective. Please note that the proposals are subject to discussion and approval by the Dutch Parliament.
Lex van Noordenburg
26 September 2023
26 September 2023

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Corporate income tax:

- A proposal to codify Dutch qualification policies for foreign legal entities and to abolish the corporate income tax liability for “open” limited partnerships (“Open CV”).
- Proposals to amend funds for joint accounts (“Fondsen voor Gemene Rekening”/FGR), tax-exempt investment institutions (“Vrijgestelde Beleggingsinstellingen”/VBI) and Fiscal investment institutions (“Fiscale Beleggingsinstelling”/FBI).
- The Energy Investment Allowance (EIA), Environmental Investment Allowance (MIA), and Random Depreciation of Environmental Investments Scheme (VAMIL) will be extended until December 31, 2028.

Personal income tax:

- A dual tax rate for substantial shareholders (5% or more) will be introduced as of 1 January 2024. Dividend income and realised capital gains are taxed at 24.5% for the first € 67,000 (€ 134,000 for tax partners) and 31% on the excess. For 2023 a current flat rate of 26.9% applies.
- Personal income in Box 3 (such as savings and investment income) is currently taxed at a flat rate of 32%. This rate will be increased by 2% as of 2024 resulting in a rate of 34%. The tax-free threshold per taxpayer will not be increased in 2024 and will remain at €57,000.

Other measures:

- The so-called 30%-ruling for expats in respect of wage taxes will be capped as of January 1, 2024.
- For real property share transactions, the value of new real property is currently exempt from VAT and RETT. The Tax Plan 2024 includes an amendment to the RETT exemption.

If you have any questions regarding this email or the Tax Plan 2024 Special, please do not hesitate to reach out to your contact person at Dirkzwager.

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