The Netherlands asks for three things, and they are not due at the same time. The information return and the notification run on a 15-month clock. The tax return runs on a 17-month clock. A group that diarises one date misses the other, and almost everyone diarises the wrong one.
The Belastingdienst waived the verzuimboete for late filing and late payment, citing international implementation problems in the first filing period. That waiver expires on 31 October 2026. Penalties resume on 1 November.
And the trap underneath it: the information return is due at 15 months, the tax return at 17. They are different obligations with different deadlines through different systems. Diarising one of them does not cover you for the other.
One regime, three deliverables, two deadlines. The information return and the notification share a clock. The tax return has its own, two months later.
| Filing | What it is | Due | Channel |
|---|---|---|---|
| Bijheffing-informatieaangifte BIA — the GIR | The GloBE information return, exchanged automatically between authorities. | 15 months after the reporting year; 18 for the first year. No extension is granted. | Digipoort (Logius) |
| Kennisgeving notification | Notification of which group entity files the BIA abroad, and in which country. | Same 15 / 18-month clock | Gegevensportaal web form — not Digipoort, not Mijn Belastingdienst Zakelijk |
| Aangifte minimumbelasting tax return | The return that assesses and pays the bijheffing itself. | 17 months after the reporting year; 20 for the first year | Mijn Belastingdienst Zakelijk |
Three filings, three different routes. Note the middle row especially: the notification does not go through either of the systems the other two use. Teams that have solved Digipoort for the BIA discover the Kennisgeving needs something else entirely.
The Netherlands has no single lead time of the German kind. It has something more awkward: two separate access mechanisms, and one of them quietly excludes the way most advisers work.
The BIA goes through Digipoort, the government's machine-to-machine gateway operated by Logius. This is system-to-system filing, not a web form, and onboarding is a project rather than a login.
The Kennisgeving needs eHerkenning with the specific service switched on. Having eHerkenning is not sufficient; the particular authorisation has to be active for that service.
Chain authorisation — ketenmachtiging — is not supported for tax service providers on the Kennisgeving. The mechanism that normally lets an adviser act for a client does not work here.
If your plan was for your adviser to handle the Dutch notification the way they handle everything else, that plan does not run. Either the client obtains eHerkenning with the service enabled and files it themselves, or you find out in the final week.
This is the second Dutch trap and it is purely procedural, which is what makes it easy to miss.
A BIA pushed through Digipoort is not filed when you push it. It is filed when the verwerkingsverslag — the processing report — comes back confirming acceptance. Until then you have transmitted something, not filed it.
Resubmission may be required. Build the processing report into your timeline as a checkpoint with time after it, not as a formality on the due date. A rejection discovered on the deadline is a missed deadline.
The Belastingdienst waived the verzuimboete for late filing and late payment, citing international implementation and system problems in the first filing period.
The waiver runs to 31 October 2026. Penalties resume on 1 November 2026.
If you have a Dutch filing that is late or about to be, the difference between dealing with it this month and next month is the difference between no penalty and a penalty.
The vergrijpboete amounts — the penalties for deliberate or grossly negligent behaviour — could not be read from the Staatscourant and are deliberately not stated here rather than guessed at.
In order. The first two are the ones that cost you time if left.
Every row was checked against the Belastingdienst's own published pages on 3 October 2026. Penalty amounts that could not be read from the primary source are left out rather than filled in.
Every row behind this guide sits in the obligation tracker, with the authority page it came from and the date it was last checked. The underlying data is open as JSON. See also the Netherlands reference page.
Take it into the meeting. The same guide as a Word document you can edit, circulate or paste into a board pack.
Download the Word versionThe scoping tool takes your whole footprint and returns every filing it triggers, in deadline order, with the access prerequisites attached. About thirty seconds.