Minimum Tax

Read this information in Dutch

The Minimum Tax Act 2024 applies to multinationals and domestic groups with a turnover of at least €750 million. The Minimum Tax rate is 15%.

The law applies to group entities that are part of a multinational or domestic group. The group must have a turnover of at least €750 million. This is based on the consolidated yearly financial statements of the group's ultimate parent entity. A group is domestic when all its entities are based in the Netherlands.

Groups that fall within the scope of this law must assess whether the effective tax rate in each country where they operate is below 15%. If the effective tax rate in a country is lower than 15%, a top-up tax applies to the difference.

GloBE Information Return

Group entities that are based in the Netherlands and fall within the scope of this law must file a GloBE Information Return, or GIR, (Bijheffing-informatieaangifte, or BIA) detailing the top-up tax for each fiscal year.

You do not have to file this return in the Netherlands if you file it in another country and we receive it through the international exchange of information. The OECD website shows the countries with which the Netherlands actively exchanges this information.

The GIR must be submitted within 15 months after the last day of the fiscal year. For the first fiscal year, the deadline is extended to 18 months.

GIR Notification

If the GIR is submitted in another country and received by us through the international exchange of information, the Dutch group entities do not need to submit the GIR themselves. However, they must notify us of this.

We must receive the GIR Notification (WMB Kennisgeving) within 15 months after the last day of the fiscal year. For the first fiscal year, the deadline is extended to 18 months.

Filing and paying a tax return

In addition to the GIR, a group must submit a tax return if a top-up tax is payable in the Netherlands for the fiscal year. The tax return must be submitted within 17 months after the end of the fiscal year. For the first fiscal year, the deadline is extended to 20 months.

Corrections to your Minimum Tax return

Have you entered an incorrect amount or other incorrect information? If so, you can correct your tax return.

More information

Would you like to learn more about the Minimum Tax Act 2024? For example, about the effective tax rate, the top-up tax or the safe harbour rule? You can find more information in the Kennisdatabank Wet minimumbelasting (Database for the Minimum Tax Act, only available in Dutch). You can also find answers to frequently asked questions in the Vraag en Antwoord wet minimumbelasting 2024 (Frequently Asked Questions about the Minimum Tax Act, only available in Dutch).
If you have any questions, you can email pijler2@belastingdienst.nl. Read more about emailing the Tax Administration of the Netherlands at belastingdienst.nl/mailen.