Luxembourg plans to cut its corporate tax rate to 15%, or 22.80% combined in Luxembourg City, from 2027. The Netherlands keeps corporate tax unchanged but proposes a 29.2% top box 2 rate for 2027–2030, a lower threshold for borrowing from your own B.V. and a smaller box 3 tax-free amount; the 27% expat ruling is already law. Belgium taxes capital gains since 2026 and cuts car deductibility further. DAC8, CBAM and AMLR reach their first deadlines in 2027.
2027: lower rates, tighter rules and a lot of proposals
The three Benelux countries move in different directions on 1 January 2027. Luxembourg cuts its corporate tax rate again. The Netherlands keeps its corporate tax unchanged but rewrites parts of the tax on owners and savers, mostly through proposals that are not yet law. Belgium is implementing the reforms of its federal government in stages, while the 2027 federal budget is still being negotiated.
On top of that, the EU brings its own calendar. 2027 is the year in which the first crypto data are exchanged under DAC8, CBAM certificates go on sale, and the new anti-money laundering regulation applies directly. Most of these rules are already enacted; what changes in 2027 is that they start to bite.
The key point for planning is status. An enacted measure can be planned around with confidence. A proposal can be planned for, but not relied on. Below, every measure carries its status as at mid-October 2026, and the checklist at the end separates what you should do now from what you should only prepare.
29.2%
Proposed top box 2 rate for 2027–2030.
22.80%
Planned combined corporate rate in Luxembourg City.
95%
Deduction for zero-emission company cars acquired from 2027.
1 February
CBAM certificates go on sale in 2027.
Netherlands: Tax Plan 2027 and the proposals of 29 September
The cabinet presented the Tax Plan 2027 on Budget Day, 15 September 2026. Two weeks later, on 29 September 2026, it added proposals for box 1, box 2 and box 3 that change the picture for owners of a B.V. and for savers. The corporate tax rates do not change.
| Measure | 2026 | 2027 | Status |
|---|---|---|---|
| Corporate tax (Vpb) | 19% to EUR 200,000; 25.8% above | Unchanged | Enacted |
| Box 1 income tax rates | 35.75% / 37.56% / 49.50% | 36.23% / 38.16% / 49.50%; top rate from EUR 80,578 | Proposed |
| Box 2 substantial interest | 24.5% to EUR 68,843; 31% above | 24.5% to EUR 69,607; 29.2% above, for 2027–2030 | Proposed (29 September 2026) |
| Excessive borrowing from own company | Threshold EUR 500,000 | EUR 420,000, then down by EUR 80,000 a year to EUR 100,000 in 2031 | Proposed (29 September 2026) |
| Box 3 tax-free amount | EUR 59,357 per person | About EUR 30,846 | Proposed (29 September 2026) |
| Box 3 deemed return on other assets | 6.00% | Up by 1.5 points (7.87%) | Proposed |
| 30% ruling for expats | 30% | 27% for new and post-2023 rulings | Enacted |
| Electric company car (bijtelling) | 18% on the first EUR 30,000 | 20% on the first EUR 30,000 | Enacted |
| Real estate transfer tax, non-owner-occupied homes | 8% | 7% | Proposed |
| Employee share options in start-ups | Taxed on exercise | Taxed on sale of the shares; 65% of the benefit taxed | Proposed, subject to EU state aid approval |
For a director-shareholder, box 2 is the headline. Dividends above EUR 68,843 per person are taxed at 31% in 2026. Under the proposal, the top rate falls to 29.2% for four years from 1 January 2027 and returns to 31% in 2031. The first bracket stays at 24.5%. The temporary cut is meant to soften a second proposal: the threshold for excessive borrowing from your own company falls from EUR 500,000 to EUR 420,000 in 2027 and then by EUR 80,000 a year to EUR 100,000 in 2031. Debts above the threshold on 31 December are taxed as a deemed dividend in box 2. Mortgage debt on the owner's home is excluded.
For savers and investors, box 3 changes again. The tax-free amount would almost halve, from EUR 59,357 to about EUR 30,846 per person, and the deemed return on investments rises by 1.5 points. From 2028 the cabinet plans a tax on actual returns, with capital gains on shares and bonds taxed on realisation. All of this is proposed, and the box 3 system has been rewritten several times since the Supreme Court ruling of December 2021.
For employees, two measures are certain. The 30% ruling becomes a 27% ruling on 1 January 2027 for everyone who first applied it in 2024 or later, and the reduced addition for new electric company cars rises from 18% to 20% on the first EUR 30,000 of the list price.
A single director-shareholder plans a dividend of EUR 300,000 from her B.V. Paid in December 2026, box 2 tax is about EUR 88,500. Paid in January 2027, and if the proposal is adopted, it is about EUR 84,300: some EUR 4,200 less. If the proposal fails, the 2027 tax is roughly the same as in 2026. Waiting is a free option, unless the cash is needed now or the shareholder plans to emigrate.
Law and practice: Tax Plan 2027 package presented on 15 September 2026; cabinet letter with additional proposals of 29 September 2026, including an amendment to the Box 3 Actual Return Bill; Wet excessief lenen bij eigen vennootschap; Wet op de loonbelasting 1964, Article 31a, as amended by the Tax Plan 2025 (27%); Wet op de loonbelasting 1964, Article 13bis, as amended by the Tax Plan 2026 (electric cars). Proposed measures need approval by both chambers.
Luxembourg: the 2027 budget bill
The Minister of Finance presented the 2027 budget bill, bill no. 8800, on 7 October 2026. It continues the policy of lowering corporate tax in steps. Luxembourg cut its corporate income tax rate from 17% to 16% in 2025; the bill takes it to 15% from tax year 2027.
| Measure | 2026 | 2027 (bill no. 8800) | Status |
|---|---|---|---|
| Corporate income tax, standard rate | 16% | 15% | Proposed (budget bill) |
| Combined rate, Luxembourg City | 23.87% | 22.80% (15% × 1.07 + 6.75%) | Proposed (budget bill) |
| Reduced rate for small profits | 14% up to EUR 175,000 | 13% up to EUR 200,000; transition band to EUR 250,000 | Proposed (budget bill) |
| Tax loss carry-forward | 17 years for losses from 2017 | No time limit | Proposed (budget bill) |
| Holding period for individuals and non-residents on capital gains (speculative gains, substantial shareholdings, non-resident gains on stakes above 10%); the SOPARFI participation exemption stays at 12 months | 6 months | 12 months | Proposed (budget bill) |
| Investment tax credit (digital and green) | 18% | 21% | Proposed (budget bill) |
| Personal tax scale | Indexed | One additional index tranche, about 2.5% | Proposed (budget bill) |
| Single tax class for individuals | Classes 1, 1a and 2 | Planned for 2028 (bill no. 8676) | Proposed |
The headline is the rate. In Luxembourg City, a company pays corporate income tax, the 7% surcharge for the employment fund on that tax, and municipal business tax of 6.75%. At 16% the combined rate is 23.87%; at 15% it is 22.80%. On a taxable profit of EUR 1 million, the saving is about EUR 10,700 a year. The bill also lowers the reduced rate for small profits from 14% to 13% and widens the bands, so small companies gain proportionally more.
Two technical changes matter for holding and investment structures. Tax losses would no longer expire after 17 years, which helps companies with long development cycles. And for individuals the holding periods for capital gains would rise from six to twelve months: speculative gains, substantial shareholdings, and non-residents who hold more than 10% of a Luxembourg company. The participation exemption for companies keeps its 12-month test. Anyone planning a short-term exit through a Luxembourg vehicle should check the timing.
For individuals, the bigger reform is not in this bill. The single tax class, which would end the difference between tax class 1 for single people and class 2 for married couples, is in bill no. 8676 and is planned for 2028. In 2027 residents get an additional adjustment of the tax scale of about 2.5%.
A Luxembourg City S.à r.l. expects EUR 600,000 of profit in 2026 and plans a EUR 100,000 marketing campaign for early 2027. Bringing the campaign forward into December 2026 moves the deduction into the year with the higher rate: the saving is the rate difference on EUR 100,000, about EUR 1,070. Small, but free, and the same logic applies to invoicing: income that legitimately belongs to January 2027 should not be invoiced in December.
Law and practice: Draft budget law for 2027, bill no. 8800, presented on 7 October 2026; Income Tax Law (LIR), Article 174 (corporate rates) and Article 114 (losses); bill no. 8676 on the single tax class. The bill is usually voted before 31 December; until then the 2027 rates are proposals.
Belgium: Arizona reforms in stages
The federal government formed in early 2025, known as the Arizona coalition, agreed a multi-year tax programme. Several parts are now law; others depend on the 2027 budget, which was still under negotiation in mid-October 2026, with a proposal to raise the standard VAT rate from 21% to 22% and merge the 6% and 12% rates into 9% on the table and contested.
| Measure | What changes | From | Status |
|---|---|---|---|
| Capital gains tax on financial assets | 10% on gains, EUR 10,000 annual exemption; pre-2026 gains exempt | Gains realised from 1 January 2026 | Enacted (law of 6 April 2026) |
| Fossil-fuel company cars ordered 1 July 2023 to 31 December 2025 | Deduction falls to 25% for 2027 costs and 0% from 2028 | 2027 | Enacted |
| Zero-emission company cars | 100% deductible if acquired by 31 December 2026; 95% if acquired in 2027, then lower | Acquisitions from 1 January 2027 | Enacted |
| Minimum director pay for the 20% SME rate | EUR 50,000, indexed; flat-rate benefits in kind count only up to 20% of pay | Under the reform law | Adopted July 2026 |
| Personal income tax reform | Tax-free amount raised in steps to EUR 15,600 by 2030; work bonus strengthened | From income year 2026 | Adopted by the Chamber on 10 July 2026 |
| Entrepreneur deduction for sole traders | 10% of profit, capped at EUR 620 | Income year 2027 | Adopted July 2026 |
| VAT rates | 22% standard; 9% merged reduced rate | Not decided | Under negotiation |
For investors, the change is already here. The capital gains tax on financial assets applies to gains realised since 1 January 2026, at 10% after an annual exemption of EUR 10,000. Gains that accrued before 2026 are protected by a step-up to the value at 31 December 2025, and specific regimes apply to substantial shareholdings. In 2027 the question is no longer whether the tax applies but how to use the annual exemption every year.
For companies, the car fleet is the practical issue. Fossil-fuel cars ordered between 1 July 2023 and the end of 2025 lose deductibility in steps: 25% for 2027 costs and nothing from 2028. Zero-emission cars acquired by 31 December 2026 remain 100% deductible; those acquired in 2027 fall to 95%. A company replacing cars in early 2027 should consider whether the order can be placed and the car acquired in 2026.
For owner-managers, the minimum remuneration that unlocks the 20% rate on the first EUR 100,000 of profit rises from EUR 45,000 to EUR 50,000, indexed, and flat-rate benefits in kind count only up to 20% of the total. A director who relies on a company car and housing to reach the threshold should check the cash salary.
Law and practice: Law of 6 April 2026 introducing the capital gains tax on financial assets, with Royal Decrees of 18 May 2026; law of 25 November 2021 on the greening of company mobility, as amended by the programme law of 2025; personal income tax reform bill adopted by the Chamber on 10 July 2026; Income Tax Code 1992, Article 215 for the reduced rate.
EU milestones in 2027
The EU calendar is mostly enacted law that reaches its first practical deadline. These dates apply in all three countries.
| Rule | 2027 milestone | Who is affected | Status |
|---|---|---|---|
| DAC8 (crypto reporting) | Tax authorities exchange 2026 data by 30 September 2027 | Crypto platforms and their users | Enacted, applies since 1 January 2026 |
| CBAM | Certificates on sale from 1 February 2027; 2026 declaration and surrender by 30 September 2027 | Importers of more than 50 tonnes of steel, aluminium, cement or fertilisers a year | Enacted |
| AML Regulation (AMLR) | Applies from 10 July 2027; EU-wide cash payment limit of EUR 10,000 | Banks, advisers, dealers, company service providers and their clients | Enacted |
| ViDA (VAT in the Digital Age) | Preparatory year; platform rules from 1 July 2028; EU digital reporting from 1 July 2030 | Platforms, cross-border sellers, all B2B traders by 2030 | Enacted |
| Pillar Two | Second year of returns; OECD side-by-side safe harbours being implemented | Groups with turnover of EUR 750 million or more | Enacted; safe harbour bill proposed in the Netherlands |
DAC8 is the one that touches private individuals. Crypto exchanges and custodians have collected data on their EU customers since 1 January 2026, and the first exchange between tax authorities takes place by 30 September 2027. A Dutch, Luxembourg or Belgian resident who has not reported crypto holdings or gains should expect the tax administration to know about them by the end of 2027.
CBAM moves from reporting to paying. The simplification regulation of 2025 introduced a 50-tonne annual threshold and moved the start of certificate sales to 1 February 2027. Importers above the threshold need authorised declarant status, must buy certificates for their 2026 imports and surrender them by 30 September 2027.
The AML Regulation replaces national rules on customer due diligence with one directly applicable regulation from 10 July 2027. For company owners the visible effect is more uniform questions from banks and advisers about ownership and source of funds, and a cap of EUR 10,000 on cash payments for goods and services across the EU.
Law and practice: Directive (EU) 2023/2226 (DAC8); Regulation (EU) 2023/956 as amended by Regulation (EU) 2025/2083 (CBAM); Regulation (EU) 2024/1624 (AMLR); Council Directive (EU) 2025/516 and related acts (ViDA); Council Directive (EU) 2022/2523 (Pillar Two) and the Dutch Minimum Tax Act 2024.
What to do before 31 December 2026
Not every change calls for action. The useful moves are those that cost nothing if a proposal fails and save money if it passes, and those that lock in an enacted rule before it tightens.
- Dutch dividends above EUR 68,843. If you can wait, pay them in January 2027. If the 29.2% proposal is adopted, the top rate falls by 1.8 points; if not, you lose nothing.
- Dutch current account with your B.V. Map the debt you owe your company on 31 December 2027 against the proposed EUR 420,000 threshold and plan repayments or a dividend to settle it.
- Dutch box 3 on 1 January 2027. Box 3 is measured on 1 January. Repaying debts that do not count, or paying deductible costs, before that date can lower the base.
- Luxembourg profit timing. Bring deductible costs into 2026 and keep income that belongs to 2027 out of December invoices, while the bill is pending.
- Belgian company cars. If you are replacing a car with a zero-emission model, acquire it by 31 December 2026 to keep 100% deductibility.
- Belgian advance payments. The last 2026 date for calendar-year companies is 21 December. A payment then still earns a 4.5% bonus against the 6.75% surcharge.
- Belgian capital gains exemption. Use the EUR 10,000 annual exemption of 2026 before the year ends; unused amounts carry forward only within limits.
- CBAM imports. If your 2026 imports of covered goods exceed 50 tonnes, check your authorised declarant status now and budget for certificates from February 2027.
- Expat employees in the Netherlands. Check which employees move from 30% to 27% on 1 January 2027 and whether salaries or contracts need adjusting.
A Dutch resident owns a Dutch holding B.V. with a Belgian operating company. She postpones a EUR 150,000 dividend from the B.V. to January 2027, has the Belgian company take delivery of two electric cars in December 2026, and pays its final advance payment by 21 December. Cost of the plan: nil. Potential saving: box 2 tax if the proposal passes, five points of car deductibility for years, and no surcharge.
Your 2027 changes and to-dos
The list updates with each choice. Status as at mid-October 2026.
What changes for you on 1 January 2027
Pick every profile that fits. You see the 2027 changes that matter to you, each tagged as enacted or proposed, and what to do before 31 December 2026.
Box 2 top rate 29.2% and lower borrowing threshold: proposed.
22.80% combined rate from 2027: in the budget bill.
Capital gains tax and car rules: enacted; VAT rates: open.
DAC8, CBAM and AMLR deadlines all fall in 2027.
Benelux tax changes 2027: frequent questions
Is the Dutch box 2 rate of 29.2% law?
No. It is a proposal the cabinet announced on 29 September 2026, after the Tax Plan 2027 was presented on 15 September. If parliament adopts it, the top box 2 rate falls from 31% to 29.2% for 2027 to 2030 and returns to 31% in 2031. Until the Senate votes, usually in December, treat it as a plan.
Is the 27% Dutch expat ruling certain?
Yes. The reduction of the tax-free allowance from 30% to 27% from 1 January 2027 is in force under the Tax Plan 2025. Employees who first applied the ruling before 2024 keep 30% for the rest of their ruling under the transitional rules.
When will Luxembourg cut its corporate tax rate?
The 2027 budget bill, presented on 7 October 2026, cuts the standard corporate income tax rate from 16% to 15% from tax year 2027. The combined rate in Luxembourg City falls from 23.87% to 22.80%. The budget is normally voted before the end of December.
Does the Belgian capital gains tax apply in 2027?
It already applies. The law of 6 April 2026 taxes gains on financial assets realised from 1 January 2026 at 10%, with an annual exemption of EUR 10,000. Gains accrued before 2026 are not taxed. 2027 is simply the second year.
When are the first CBAM certificates due?
Sales of CBAM certificates start on 1 February 2027. Authorised declarants who imported more than 50 tonnes of covered goods in 2026 declare their 2026 emissions and surrender certificates by 30 September 2027.
What is the single tax class in Luxembourg?
A reform that replaces the current tax classes 1, 1a and 2 with one class for all individuals. It is in a separate bill and is planned for 2028, not 2027. The 2027 budget adjusts the tax scale by one additional index tranche of about 2.5% in the meantime.