Netherlands Pillar Two: notification by 30 June, top-up tax return by 31 August 2026

Country reference

• Country: Netherlands (planned expansion country)
• Authorities: Netherlands Tax Administration (Belastingdienst)
• Topic: Pillar Two compliance under the Minimum Tax Act 2024
• Key date: Portal opened 2 June 2026; notification 30 June 2026; return and payment 31 August 2026
• Law: Minimum Tax Act 2024 (Wet minimumbelasting 2024)

The obligations

• Notification: a registration with the tax authorities, not a return, filed through the Dutch data portal with eHerkenning.
• Information: the ultimate parent entity, tax numbers, GloBE information return status and who filed it.
• Top-up tax return and payment: only where a Dutch top-up tax liability arises.

Key dates for the first year

• Portal opened: 2 June 2026.
• Notification deadline: 30 June 2026.
• Top-up tax return and payment: 31 August 2026, where relevant.

Scope

The EUR 750 million threshold applies to the whole group, so a small Dutch entity can still have to file.

Coming changes

The Tax Plan 2027 package includes a separate bill adding OECD side-by-side safe harbours, with retroactive effect for certain years.

What to do now

• Confirm the notification was filed for every Dutch entity.
• If not, contact the tax authorities and file without delay; late filing can lead to penalties.
• Plan for the next cycle and the safe harbour changes.

Our take

Many Gulf groups own Dutch holding or trading companies. Even where no Dutch top-up tax is due, the notification is required.