On 10 December, the State Secretary of Finance published two important decrees regarding the VAT position of holding companies. These decrees replace, among others, the Holding decree (holdingresolutie) and provide guidance on the VAT deduction right of holding companies and their inclusion in the VAT group.
The VAT deduction right for shareholding activities is an ongoing topic of discussion between businesses and the Dutch tax authorities. These changes will take effect on July 1, 2025, and may have a broad impact on the VAT deduction right in relation to holding activities.
The decrees that will be withdrawn are regularly invoked in practice in discussions and agreements between businesses and the tax authorities regarding (the extent of) the right to deduct VAT for holding companies. As these decrees are being withdrawn, it is important to determine the consequences and adjust the tax strategy accordingly. It is important to assess how the amended policy affects the VAT deduction right.
