Field guide · Netherlands · October 2026

Three filings. Two different clocks.

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.

Checked 3 Oct 2026 Primary-sourced 7 min read
Start here, if you read nothing else

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.

01The two clocks, which is the whole story

One regime, three deliverables, two deadlines. The information return and the notification share a clock. The tax return has its own, two months later.

FilingWhat it isDueChannel
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 clockGegevensportaal 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 yearMijn 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.

02Two access routes, and a trap for advisers

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.

Digipoort, for the information return

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.

eHerkenning, for the notification

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.

The part that catches advisory firms

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.

03Submitted is not the same as filed

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.

04Penalties, and the waiver that expires this month

The Belastingdienst waived the verzuimboete for late filing and late payment, citing international implementation and system problems in the first filing period.

The date that matters

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.

05A ninety-day checklist

In order. The first two are the ones that cost you time if left.

  • Diarise two Dutch dates, not one: the information return at 15 months and the tax return at 17.
  • Establish today whether anything Dutch is late. The penalty waiver ends 31 October 2026 and that is the cheapest deadline you will ever meet.
  • Confirm who holds eHerkenning with the Kennisgeving service enabled. If the answer is "our adviser", that answer is wrong — chain authorisation does not work here.
  • Check Digipoort onboarding status for the BIA. It is machine-to-machine filing and is not solved by having a login.
  • Add the verwerkingsverslag to your timeline as a checkpoint with slack after it, not as a box ticked on the due date.
  • Establish whether your BIA is filed in the Netherlands or abroad. If abroad, the Kennisgeving is your obligation and it carries the same deadline.
  • Note that no extension is granted on the information return. There is no Dutch equivalent of a filing extension to fall back on.

06Where every statement above comes from

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 version

The Netherlands is one of twenty jurisdictions on this site.

The scoping tool takes your whole footprint and returns every filing it triggers, in deadline order, with the access prerequisites attached. About thirty seconds.