Major changes as of 1 January 2026
As of 1 January 2026, the Dutch VAT revision regime (herzieningsregeling) will change significantly. The scope of the revision rules will be expanded to include certain costly services related to real estate, in addition to goods. This development is highly relevant for real estate owners, investors, and developers.
Under the current VAT rules, the revision regime mainly applies to capital goods, such as immovable property, typically over a 10-year revision period. Services, even if expensive and closely linked to real estate, generally allow immediate VAT deduction.
These changes may directly affect the deductibility of VAT on renovation, improvement, and redevelopment projects.
When does VAT revision apply to services?
VAT revision will apply if all of the following conditions are met:
- The service is directly linked to real estate
- The cost exceeds €30,000 per individual service
- The service has a useful life extending over multiple years
- The first use takes place on or after 1 January 2026
If these criteria are met, VAT must be revised over a five-year period.
Practical examples
- A single renovation service with a cost of €50,000 may trigger VAT revision if the use of the property changes within five years.
- Multiple services below the €30,000 threshold, performed by different contractors, will generally not fall within the revision regime, provided they qualify as separate services.
The classification of services therefore plays a key role in practice.
Why is this change being introduced?
The legislator aims to prevent situations where VAT remains fully deductible despite short-term or changing use of real estate. This can occur, for example, where a property is initially used for taxable activities and later for VAT-exempt purposes.
Such outcomes were considered inconsistent with the principle of VAT neutrality, as VAT deduction did not accurately reflect the long-term use of the property.
Key points of attention
The new rules raise several practical and interpretative questions, including:
- What qualifies as a single service?– When should multiple works be treated as one composite service?
- When is a service considered “put into use”? – This moment determines whether the revision regime applies.
- Major renovations and the revision period – In the case of substantial renovation, the question arises whether a 10-year revision period may apply, and under which conditions.
Further clarification through legislation, policy guidance, or case law is expected.
Conclusion
The extension of the VAT revision regime to costly real estate-related services increases the importance of timely VAT planning. While the new rules aim to achieve a more neutral VAT outcome, they also introduce additional complexity.
If you require assistance, our colleagues can support you with VAT representation and advise you on all relevant VAT matters, ensuring compliance and an optimal VAT position.
