Pillar Two Dashboard: The Netherlands Articles

The Netherlands has announced the opening of its Pillar Two filing from June 2026.

On 9 and 10 April 2026, the Dutch Tax Administration’s Pillar Two Knowledge Group published two administrative positions on the treatment of joint ventures under the Dutch Minimum Tax Act 2024.

Part III of the Dutch Year-End Decree 2025 (published in the Official Gazette on December 23, 2025) amends the Minimum Tax Executive Decree 2024 for aspects of the December 2023, June 2024, and January 2025 OECD Administrative Guidance.

On December 16, 2025, The Netherlands Parliament approved the Second Amendment to the Minimum Tax Act to implement the December 2023, June 2024 and January 2025 OECD Administrative Guidance.

The Dutch Minimum Tax Executive Decree 2024 was published in the Government Gazette on December 23, 2024 to implement various aspects of the OECD Administrative Guidance.

On December 17, 2024, the Dutch Parliament approved a draft law to amend the GMT Law. This includes a number of amendments to implement further aspects of the February 2023 and July 2023 OECD Administrative Guidance and some aspects of the December 2023 OECD Administrative Guidance.