New Dutch VAT Policy Changes for Holding Companies Effective July 2025

• The VAT position of holding companies is often discussed with the Dutch Tax Authorities
• Two new VAT policy decrees for holding companies will be effective from 1 July 2025
• Holding companies are advised to review their current VAT positions ahead of these changesFirst Decree details
• Revises policies on input VAT deduction for share transactions
• Removes the requirement of a majority interest for VAT scope in management interference scenarios
• Includes specific examples where shares in a subsidiary are considered an extension of the holding company’s economic activity
• Covers trading in shares and securities as part of business activitiesSecond Decree details
• Concerns tax liability of officials and VAT grouping for holding companies
• Maintains that holding companies engaged in management and policy activities can be part of a VAT group
• Extends VAT group eligibility to intermediate holding companies
• Provides guidelines on interpreting conditions for VAT grouping based on financial, organizational, and economic tiesAdditional points
• Current VAT policies codified in the Holding Resolution and the Sale of Shares Decree will be revoked on 1 July 2025
• New policies address the allocation of costs in share transactions and the impact on the pro rata right to deduct input VAT
• Specifies that proceeds from incidental financial activities like the sale of shares can be excluded from VAT calculation calculations

Source: insightplus.bakermckenzie.com

Note that this post was (partially) written with the help of AI. It is always useful to review the original source material, and where needed to obtain (local) advice from a specialist.

---

---