| On June 24, 2026, the European Commission presented the so-called Taxation Omnibus package. The aim of this proposal is to significantly simplify the tax system, reduce administrative burdens, and stimulate investment within the EU. Below are the key elements of this package. |
The core of the proposal is to make the tax system within the EU simpler and more efficient while promoting investment, growth, and competitiveness within the single market. Key elements include a significant reduction in administrative burdens, with companies expected to benefit from total cost savings of approximately €6.6 billion per year.
Exemption from Withholding Taxes
Currently, dividend, interest, and royalty payments are often subject to withholding tax in the source country, after which foreign shareholders—depending on the application of tax treaties—must claim a (partial) exemption or refund, a process that is administratively burdensome and time-consuming. A key change introduced by this Omnibus package is the elimination of withholding taxes on dividend, interest, and royalty payments between companies within the EU. This lowers the tax barriers to cross-border investments and makes it easier to circulate capital within corporate structures without complex refund and exemption procedures.
Simplification and Relaxation of Interest Deduction Limits
In addition, the general interest deduction limitation will be simplified and harmonized. This limitation means that the deduction of net interest is capped at a fixed threshold or (if higher) a percentage of taxable EBITDA, above which the limitation applies. While Member States are currently still permitted to apply stricter national limitations, it is proposed to mandate a single uniform standard: a maximum of 30% of taxable EBITDA and a threshold of €3 million (with subsequent indexation). Under certain conditions, interest on loans from third parties—unlike the current implementation in the Netherlands—must remain outside the limitation. It is also proposed that the so-called “group escape” be made mandatory, allowing taxpayers to claim a higher interest deduction if they demonstrate that their leverage is in line with that of the group as a whole—an important concession for capital-intensive sectors. It is also important that a provision addressing procyclical effects be introduced. In short, this means that the interest deduction limitation does not always apply when taxable EBITDA declines by 50% or more compared to the previous year. All in all, this means that countries such as the Netherlands—where a stricter 24.5% cap and a €1 million threshold currently apply, third-party loans are subject to the limitation, and there is no “group escape” provision—will need to relax their rules. This leads to greater predictability and, in many cases, to broader deduction options.
Deduction for R&D Expenses
One of the proposed measures is that, within the EU, investments in R&D can be immediately and fully deducted from profits for tax purposes, thereby generating a tax benefit. Currently, the Netherlands already has a scheme under which the production costs of intangible fixed assets can be written off in a single year. In addition, the Netherlands currently supports R&D from a tax perspective through schemes such as the WBSO and the innovation box.
Impact on Investors
For Dutch investors, the impact lies primarily in the overlap with the proposed Box 3 reform. The current proposal would make it more tax-advantageous in the future to hold investments within a private limited company (BV), as this would allow for the use of the announced European exemptions on dividend flows. The Dutch participation exemption currently applies only to holdings of 5% or more, but under the proposal, it would in principle also apply to dividends received from smaller equity holdings. This could make it more attractive to hold equity investments within a BV rather than privately.
In conclusion
The proposals still need to be approved by all member states and are not expected to take effect until 2029 at the earliest (with some changes not taking effect until 2032 or even 2037). However, the direction is clear: less complexity, lower burdens, and more room for investment. We will continue to monitor these developments. As soon as there is more certainty, we will get back to you with specific insights.