Spring Memorandum 2024 | Additional Expenditures and Coverages

Case

The Spring Memorandum includes adjustments to the 2024 budget, as well as an outlook on the budgets for the coming years. Due to the early publication, the spring decision calculations from the CPB, the spring report as part of the Council of State's budget review, and the cabinet response will follow at a later date, no later than April 30, 2024.

Additional Expenditures

The additional expenditures included in the Spring Memorandum are:

• An extra €4.4 billion for military and humanitarian aid to Ukraine for the years 2024-2026.
• An additional €0.4 billion in 2024 and an extra €0.9 billion in 2025 for the recovery operation Toeslagen.
• An extra €0.5 billion in 2025 for residents in the earthquake area in Groningen.
• A structural €715 million extra from 2026 for decentralized authorities.
• An incidental €500 million extra in 2028 for the reinforcement of air defense and ammunition for the armed forces.

Additional setbacks in the budget

The budget also faces several significant setbacks, including an additional €375 million in 2024 and an extra €700 million in 2025 allocated to the Central Agency for the Reception of Asylum Seekers (COA) for both new and existing emergency (crisis) reception facilities.

Disappointing revenues

Alongside the extra expenditures, there are disappointing revenues, partly due to the retention of the net-metering scheme for solar panels and the elimination of the energy tax for heavy industry. Additionally, a phased reduction of the motor vehicle tax (mrb) exemption for zero-emission passenger cars has been agreed upon, with a discount on mrb for these vehicles set at 40% from 2026, 35% in 2029, and 30% in 2030.

Coverage

A portion of the additional expenditure will be offset by windfalls in various budget categories. The windfall revenues will be covered by, among other sources:

• Lowering the SME Profit Exemption: The SME profit exemption will be reduced further to 12.03% from 2025, instead of the previously planned reduction to 12.7%.
• Adjustment to the Highest Income Tax Rate: The starting point of the highest income tax rate (49.5%) will be lowered by €557 in 2025. Initially, an increase of €1,000 to €1,100 compared to 2024 was planned, making this increase €557 lower than anticipated.
• Non-extension of SEPP Purchase Subsidy: The purchase subsidy for used electric passenger cars (SEPP) will not be extended beyond 2025. Although funds were allocated for the period 2025 to 2029, the SEPP extension will not proceed.
• Integration of PHEV into Regular bpm Table: A separate bpm table for plug-in hybrid-powered passenger cars (PHEV) will be eliminated from 2025, with PHEVs being included in the regular bpm table.
• Inflation Adjustment for Company Van Tax: The fixed amount for the final tax on the private use of company vans, alternately used by multiple employees (€300), will be adjusted for inflation. This amount has remained unchanged since its introduction in 2006.
• Increase in Energy Tax Rates: The rates for the 3rd, 4th, and 5th tranches in the energy tax on natural gas will increase by 22.4% by 2025 and an additional 2.7% by 2030.
• Abolition of Exemption for Dual and Non-Energy Consumption Coal: The exemption for dual and non-energy consumption coal will be abolished by 2027.

Note! In August, the cabinet will reassess whether further budget adjustments are necessary, which may also involve reconsidering the coverage.

Notable Tax Constructions

In Annex 10 to the Spring Memorandum, the government provides an update on several notable tax constructions. The government plans to address the following constructions through legislation in the Tax Plan 2025, the Fiscal Collective Act 2025, or the End of Year Decree 2024:

• Plot Exchange Exemption in Transfer Tax: Measures to address constructions related to the plot exchange exemption in transfer tax.
• Short-term Rental Constructions in VAT: Actions to tackle short-term rental constructions affecting VAT.
• Tax Avoidance via Division Exemption in Real Estate Transfer Tax: Initiatives to combat tax avoidance through the division exemption in real estate transfer tax.
• Cropping Up Behavior in Property CVs: Measures to prevent cropping up behavior in property CVs aimed at maximizing interest deductions.
• Tax Avoidance via Non-Regular Settlement of Pension Entitlements in the PLC: Steps to address tax avoidance through non-regular settlement of pension entitlements in the PLC.

The government is also examining whether additional legislation is required and desirable to address constructions that evade taxation in box 3 through share premium payments and asset repurchases. Regarding a construction related to the lucrative interest scheme, on which a motion was passed on April 9, the Chamber will receive further information before the summer recess of 2024.