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IP box Active

Innovation Box (Innovatiebox)

Preferential taxation of qualifying IP income at an effective rate of 9% instead of the 25.8% headline rate. Nexus-conform under the OECD BEPS Action 5 modified nexus approach: the benefit scales with the R&D the taxpayer performs itself. Applied by self-assessment in the corporate tax return.

3 Jul 2026

Key parameters

Effective rate on qualifying IP income 9%
Nexus conformity Yes — OECD BEPS Action 5 modified nexus approach
Access ticket WBSO S&O declaration; patents/plant-breeder rights for larger taxpayers Small taxpayers can qualify with WBSO alone
Policy stability Maintained per coalition agreement (confirmed 2025/2026)

Eligibility

HQ
Any headquarters country
Local presence
Local tax presence required (branch is sufficient) A branch office (Zweigniederlassung/permanent establishment) of your existing company is enough — you do not need to form a new legal entity such as a GmbH or BV.
R&D substance
Required
Company size
No size restriction
Revenue
Bounded above €750M (Pillar Two 15% floor)
Models
Fabless design, IP licensing, IDM, EDA / tools
Sectors
All
Goals
IP domiciliation; Additional design site in Europe

Qualifying IP must result from R&D performed by the Dutch taxpayer (nexus ratio). For groups above the €750M Pillar Two threshold, the effective benefit is bounded by the 15% GloBE minimum.

Mechanism & application

Rule-based entitlement — Legal entitlement — self-assessment, no case-by-case funding decision.

Self-assessment in the corporate income tax return; most taxpayers agree the innovation-box allocation method with the Belastingdienst in an advance tax ruling for certainty.

Timeline: Immediate (tax filing); advance ruling typically 3–6 months

Legal basis & sources

Legal basis
Art. 12b Wet op de vennootschapsbelasting 1969
Source
https://wetten.overheid.nl/BWBR0002672/
Verification
Wet Vpb 1969 consolidated text / coalition agreement 2025
from 1 Jan 2010 until no expiry review 1 Jan 2027

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