In our earlier news release, we informed you about the Supreme Court ruling of January 16, 2026. In it, the Supreme Court ruled that the increase in tax interest for corporate income tax (Vpb) relative to other taxes violates the principles of proportionality and equality.
On Feb. 25, 2026, the inspector issued two collective rulings on objections in the mass objection procedures on tax interest for corporate income tax (Vpb) and for income tax & other taxes. The objections for Vpb were upheld; those for income tax & other taxes were declared unfounded. In this article, we provide you with an update.
Corporate tax
On Feb. 25, 2026, in a collective ruling on objections, the inspector declared all objections in the mass objection procedure against tax interest for corporate income tax (and some other taxes) well-founded.
As a result, tax interest for Vpb is calculated at the interest rate applicable to other taxes (including income tax). This results in the following rates:
Period% (becomes) (was)
From January 1, 2022 through June 30, 2023: 4%8%
From July 1, 2023 to December 31, 2023: 6%8%
About 2024: 7,5%10%
About 2025: 6,5%9%
As of 2026: 5%7,5%
You will not receive a separate ruling on objections yourself. You will automatically receive a reduction of the tax interest within six months if an objection is filed in time within the mass objection procedure. The Tax Office automatically adjusts assessments imposed after the Supreme Court ruling where necessary.
Income tax and other taxes
On Feb. 25, 2026, in a collective ruling on objections, the inspector declared all objections in the mass objection procedure on tax interest for income tax and other taxes (such as inheritance and gift tax, payroll tax and sales tax) unfounded. There is no appeal against this collective ruling. You will also not receive an individual ruling on objection.
In its April 10, 2026 ruling, the Supreme Court expressly confirmed that tax interest for income tax and other taxes does indeed not violate the principle of proportionality.
Conclusion
For corporate income tax, the mass objection tax interest has been declared well-founded. If you are eligible (after timely objection) for a reduction of tax interest for corporate income tax, you can expect it in principle within six months. For income tax and other taxes, the mass objection was rejected.
Do you have any questions as a result of this post? Please feel free to contact your relationship manager or via our general
040 2 504 504 phone number.