Netherlands · Pillar Two · In force

Netherlands Pillar Two obligations

Netherlands imposes 3 separate filing obligations under Pillar Two. The earliest is Bijheffing-informatieaangifte, due 15 months after the reporting year; 18 months for the first year. No extension is granted.. Checked against the authority on 3 October 2026.

Checked 3 October 2026 Primary-sourced 3 separate filing obligations

Three separate deliverables on two different clocks — information return at 15/18 months, tax return at 17/20.

Access gate — clear this before anything can be filed

Digipoort onboarding (BIA) / eHerkenning (Kennisgeving)

Two different access routes for two obligations. The notification needs eHerkenning with the specific service switched on — chain authorisation (ketenmachtiging) is NOT supported for tax service providers.

What is in force in Netherlands

Charge	Local name	In force from
IIR	Inkomen-inclusiebijheffing	Law in force from 31 Dec 2023
UTPR	Onderbelastewinstbijheffing	Unconfirmed — statutory text not retrievable
Domestic	Binnenlandse bijheffing	Law in force from 31 Dec 2023

The 3 separate filing obligations

Bijheffing-informatieaangifte

Also: BIA · GIR

The GloBE information return, exchanged automatically between authorities.

Who files: Dutch group entities, unless filed abroad and received by NL through exchange
Deadline: 15 months after the reporting year; 18 months for the first year. No extension is granted.
Channel: Digipoort (Logius). Filed only once the verwerkingsverslag confirms acceptance — resubmission may be required.

Bijheffing-informatieaangifte — Belastingdienst ↗

Kennisgeving

Also: notification

Notification of which group entity files the BIA abroad, and in which country.

Who files: Dutch group entities whose BIA is filed abroad
Deadline: 15 months after the reporting year; 18 months for the first year
Channel: Gegevensportaal web form — not Digipoort, not Mijn Belastingdienst Zakelijk. Requires eHerkenning.

Kennisgeving — Belastingdienst ↗

Aangifte minimumbelasting

Also: tax return

The return assessing and paying the bijheffing itself.

Who files: Groups owing bijheffing in the Netherlands
Deadline: 17 months after the reporting year; 20 months for the first year — a different clock from the BIA
Channel: Mijn Belastingdienst Zakelijk

Minimumbelasting: aangifte doen en betalen — Belastingdienst ↗

Penalties

Verzuimboete waived for late filing or payment through 31 October 2026, citing international implementation and system problems in the first filing period. Penalties resume 1 November 2026. Vergrijpboete amounts unconfirmed from primary source.

What catches groups out in Netherlands

The two clocks are the trap — a group that diarises one date misses the other.
Acceptance is not submission: until the verwerkingsverslag confirms, the BIA is not filed.
Penalty waiver expires 31 October 2026.

Recent changes affecting Netherlands

2026-10-31 — Dutch penalty waiver expires. Penalties resume from 1 November 2026.
2026-08-31 — First Dutch minimum tax return deadline for the 2024 reporting year under the 20-month rule.
2026-08-18 — Verzuimboete waived for late minimum tax filing or payment through 31 October 2026, citing international implementation and system problems.
2026-07-20 — Processing reports (verwerkingsverslag) become available — until then acceptance of a BIA could not be confirmed.

All dated changes →

Common questions

What must be filed in Netherlands under Pillar Two?

3 separate obligations: Bijheffing-informatieaangifte; Kennisgeving; Aangifte minimumbelasting.

When is the Bijheffing-informatieaangifte due in Netherlands?

15 months after the reporting year; 18 months for the first year. No extension is granted.. Filed by: Dutch group entities, unless filed abroad and received by NL through exchange. Channel: Digipoort (Logius). Filed only once the verwerkingsverslag confirms acceptance — resubmission may be required..

When is the Kennisgeving due in Netherlands?

15 months after the reporting year; 18 months for the first year. Filed by: Dutch group entities whose BIA is filed abroad. Channel: Gegevensportaal web form — not Digipoort, not Mijn Belastingdienst Zakelijk. Requires eHerkenning..

What access is needed before filing in Netherlands?

Digipoort onboarding (BIA) / eHerkenning (Kennisgeving). Two different access routes for two obligations. The notification needs eHerkenning with the specific service switched on — chain authorisation (ketenmachtiging) is NOT supported for tax service providers.

What are the penalties in Netherlands?

Where this comes from

Every row on this page was checked against the authority's own published page on 3 October 2026. Obligations verified against Belastingdienst pages. Penalty amounts could not be read from the Staatscourant and are not stated.

Cite this page

Saurabh Satija, “Netherlands Pillar Two filing obligations”, https://saurabhsatija.com/pillar-two-netherlands, accessed [date].

Quotation and citation with attribution and a link are welcome. The underlying data is open as JSON and as plain text.

Other Pillar Two jurisdictions

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