Reduction in transfer tax for private investors
Within the transfer tax, a rate reduction will be implemented for private investors. The rate for the acquisition of homes that do not serve as a principal residence, such as rental and vacation homes, will be reduced from 8% to 7% by 2027. This measure constitutes a tax break on real estate transactions and changes the existing balance between home ownership and real estate investment. Whereas previous policy measures were aimed precisely at increasing the tax burden for investors, a limited reduction in the rate is now chosen. Generic interest deduction limitation (a.o. for real estate companies)
In addition, the cabinet is focusing on so-called 'haircutting' behavior of companies to make optimal use of interest deduction within corporate income tax. This construction is again on the list of notable tax constructions. Although the earlier anti-fragmentation measure was ultimately not introduced, additional anti-abuse measures are currently being examined, based in part on regulations in other EU countries. The purpose of this exploration is to prevent taxpayers from circumventing the operation of interest deduction limitations through artificial structuring and thereby reducing their effective tax burden. According to the legislator, this is particularly the case with real estate companies, where a separate company is used for each individual real estate project. Paper donations
The Spring Memorandum 2026 pays explicit attention to paper donations as an undesirable tax construct. These are donations in which the assets are legally transferred but not actually paid out to the donee yet, thus preserving liquidity with the donor. The government is investigating measures to make this construction less attractive. These include a lower interest rate and considering such donations as notional acquisitions for gift and inheritance tax purposes. The aim of these adjustments is to limit the tax benefit of paper donations and bring taxation more in line with economic reality. Valuation of homes for gift tax purposes
A previously announced measure to value homes for gift tax purposes at fair market value instead of the WOZ value will not be introduced. The implementation test has shown that this change is not feasible. This means that for the time being the WOZ value will remain the starting point for the fiscal valuation of homes upon donation. In practice, this usually leads to a lower valuation than the market value, as a result of which the tax burden when real estate is transferred by gift remains limited compared to the previously proposed situation. Freezing income tax brackets and increasing Aof premium
The various measures of the new cabinet in the areas of defense and health care lead to lower government revenues and higher -expenditure. This will be compensated by a limited application of the inflation adjustment in the income tax rate brackets. In addition, the Aof premium rate will be increased. Delay introduction of lump sum on retirement
The Cabinet proposes to delay the introduction of the Lump Sum Review Act from July 1, 2026 to January 1, 2029. This law should make it possible in the future to withdraw up to 10% of the accrued pension in one lump sum upon retirement. Conclusion
The tax measures in the Spring Memorandum 2026 show a clear policy direction in which the Cabinet wishes to more emphatically combat what they consider to be notable tax constructions. For taxpayers, this means that the tax position may change and adjustment may be desirable. Do you have questions about what these measures mean for you or your company? Then please contact us through your relationship manager, by phone at 040 - 2 504 504 or via the contact form below. | 