Dutch companies can pay loan interest now while part of the tax deduction is delayed. In 2026, the generic limit applies when net interest exceeds both 24.5% of profit and €1 million. Qualifying property entities can have a zero threshold. The gap can increase taxable profit and tighten cash.
Why this matters
Interest leaves the bank on its payment date. The deduction depends on taxable profit and room under the limit. Disallowed interest may carry forward. It can be used only when later profit provides deduction room. Lower rent, a weak trading year, or refinancing can reduce that room. In 2026, corporate income tax is 19% up to €200,000 of taxable profit and 25.8% above it. Qualifying property entities have no €1 million threshold.
Example
A BV owns a commercial building rented to external tenants. Rent covers interest, maintenance and repayment. Its accounts record the full interest cost. The tax calculation may deduct only part of that interest this year. Taxable profit can then exceed the accounting result. The BV pays the lender and may owe more current tax. Carried-forward interest helps only when later profit leaves enough deduction room. The owner needs one forecast for rent, interest, repayment, tax and carried-forward interest.
XTROVERSO tips
- Map every material loan. Record the lender, borrower, rate, security, repayment date and business purpose. Match each loan to the legal entity earning the related income.
- Add tax timing to the cash forecast. Show interest paid, interest deductible this year and interest carried forward as separate lines in the planning file.
- Check property entities separately. Review the asset mix and rental relationships. Confirm whether at least 70% of assets are property rented outside the group.
- Review cross-border payment routes. Check related parties, ownership percentages, receiving jurisdictions and payment flows. Include interest, royalties and dividends in the review.
- Test the file before signing. Compare the contract, entity chart, bank movements, accounts and tax position before refinancing or restructuring. They should describe the same financing arrangement.
Need a clear view of debt, tax deductions and cash timing? XTROVERSO can review the file before you sign or refinance
The data, sourcing, and analysis behind this article were conducted by Linda Pavan. AI was not used to identify sources, build the factual basis, or produce the analytical judgment contained here. AI was used only as a drafting aid. The final English text was personally reviewed, edited, and approved by Linda Pavan before publication.
References
- Taxence — Kabinet kritisch op versoepeling Europese renteaftrekbeperking
- Belastingdienst — Changes to Dutch corporate income tax in 2026
- Rijksoverheid — Effect of the earnings-stripping measure
- Rijksoverheid — Property measure and anti-fragmentation rules
- Belastingdienst — Withholding tax on interest and royalties
- Belastingdienst — Dutch participation exemption and 5% boundary
- Rijksoverheid — Research into abuse of the earnings-stripping measure
- Wettenbank — Corporate Income Tax Act 1969, Article 15b
