Global Daily Tax News, Dutch Tax Agency Still Working To Correct Overcharged CIT Interest, (Sep 3, 2026)

On August 28, 2026, the Dutch tax authority provided an update on work to reduce certain taxpayers' corporate income tax assessments, following a court ruling that the interest rate assessed on corporate income tax late payments was too high.

On November 7, 2024, the District Court of the Northern Netherlands (Rechtbank Noord-Nederland) ruled that the interest rate for corporate income tax is too high and therefore in conflict with the principle of proportionality. Dutch authorities submitted an appeal to the Supreme Court.

In a May 8, 2025, statement, the tax agency confirmed that it had received additional complaints from taxpayers, notably on amounts charged for other taxes. These were grouped as a "mass objection" in April 2025.

The Supreme Court subsequently ruled that the higher rate of interest charged for corporate income tax underpayments may not be applied. However, the Supreme Court ruled against the mass objection appeal concerning other taxes.

In response, on February 25, 2026, a collective ruling was issued by the Tax and Customs Administration inspector confirming the implementation of the Supreme Court's ruling in relation to interest payable on late payments for levies other than corporate tax. It dismisses these claims and confirms that taxpayers cannot appeal this ruling as the Supreme Court's ruling is final.

In July, the Dutch tax agency confirmed it was working to correct assessments covered by the mass objection concerning corporate income tax. It said at the time it would also amend assessments where objections were filed shortly after the Supreme Court's ruling, between January 16, 2026, and February 14, 2026.

In its August 28, 2026, update, the tax authority said: "Almost all objections falling under the collective ruling on the mass objection have now been processed. A small number are still being processed: often more complex situations where multiple objections are assessed together."

"As a result, it has not been possible to meet the aforementioned deadline in all cases [of six months from the issuance of the collective ruling]. The Tax and Customs Administration wishes to process these files carefully and as quickly as possible. You do not need to do anything for this."

The tax agency also confirmed that it is working to reduce the assessments of those taxpayers who submitted objections between January 16, 2026, and February 14, 2026, stating the agency is taking a phased approach, with a focus first on amending final assessments.