Minimum tax
On 31 December 2023, the Minimum Tax Act 2024 (GMT) came into effect. Profits of multinational and domestic groups with an annual turnover of at least €750 million are subject to a minimum tax rate of 15%. The law applies to group entities of both multinational and domestic groups, based on the consolidated financial statements of the group's ultimate parent entity. Domestic groups are those where all entities are based in the Netherlands. If a group falls within the scope of this law, it must assess whether the effective tax rate in each country where it operates is below 15%. If the effective tax rate in a country is lower, a top-up tax will be applied to cover 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.
GIR Notification
If the GloBE Information Return, or GIR, (Bijheffing-informatieaangifte, or BIA) is filed in another country and received by us through the international exchange of information, the Dutch group entities do not need to file the GIR themselves. However, they do have an obligation to notify: they must let us know which group entity filed the GIR and in which country.
Minimum tax: filing and paying a tax return
A group must file a tax return if they had to pay a top-up tax on the fiscal year in the Netherlands. You submit the Minimum Tax return through Mijn Belastingdienst Zakelijk. 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.
Objection to paid Minimum Tax amount
If you disagree with the amount you paid for your Minimum Tax return, you can lodge an objection within 6 weeks of the payment date.
Corrections to your Minimum Tax return
Do you want to correct something in your tax return? How you can do this depends on your situation. Select the situation that applies to you below. You can correct your Minimum Tax return in Mijn Belastingdienst Zakelijk.
