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As we start the new year, we have prepared an overview of the key Dutch and international tax developments impacting the shipping and offshore services industry.
This annual update summarises the most relevant changes in corporate income tax, Pillar Two, VAT, and wage tax/social security for the shipping and offshore sector in the Netherlands for 2026. In addition, we review key developments from 2025 and highlight important EU and international developments that may influence the industry in the year ahead.
Corporate income tax
Key developments for 2026 include the updated corporate income tax rates, the national exemption to the EU/EEA flag requirement and changes affecting offshore working vessels. We also outline the application of the OECD's GloBE rules, the international shipping income exclusion, the substance‑based income exclusion and the transitional and permanent safe harbour provisions. In addition, we highlight a recent EU court case concerning the ISI exclusion and European tonnage tax regimes.
Value added tax
For VAT, we briefly address the implications of transfer pricing arrangements, which continue to be relevant for multinational groups active in the shipping and offshore services sector.
Wage taxes
Recent wage tax developments include clarification of the application of the WVA to offshore support vessels, as well as equal‑pay decisions in the Netherlands that may affect employers in the industry.
EU and international developments
We also highlight key regulatory and international developments, including FuelEU Maritime, the Carbon Border Adjustment Mechanism, the judgment in case C‑137/23 (Alsen), the implications of the EU ETS for customs valuation and the introduction of a new Article 8 in the UN Model Tax Convention.
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The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.