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Version 22 - February 2025 (CUD release)

Content update

This document provides confirmation to our stakeholders that the Netherlands Corporate Template contains Illustrative Model Content with legislative coverage for annual year end reporting until December 31, 2025.
  • Financial Period Type: 12-Months (Annual)
  • Target Industry Type: Manufacturing, Services, and Generic (excluding Financial Services).

Legislative updates

Changes in Dutch Accounting Standard (DAS) Chapter 271 “Employee Benefits”
DAS-Statement 2024-17 discusses vitality schemes and early retirement schemes. It treats early retirement schemes separately because they differ in nature from vitality schemes. In early retirement schemes, individuals aren't required to perform work, even if a formal employment relationship still exists.
Vitality schemes
The changes for vitality schemes include:
  • Examples of rewards where rights are accrued and rewards where no rights are accrued.
  • Rights are accrued:
    An employee working at 80% capacity while retaining full or partial salary and/or pension accrual must meet certain conditions. The employee should have been employed for at least 5 years and be at least 58 years old. If there is a service year requirement, rights are accrued unless the condition holds no or only minor economic significance.
  • No rights are accrued:
    Continued payment in case of maternity or parental leave or future salary increases based on salary scales.
For schemes that allow paid absence for part of the working time, it is important to assess the economic reality of the scheme to determine if it constitutes a reward with rights accrual or without rights accrual. If rights are accrued, an obligation must be recognized and valued at the best estimate of the amounts needed to settle it. For schemes without rights accrual, expenses are recognized in the period the reward is due. Additional disclosure requirements apply to vitality schemes.
These include:
  • The main characteristics of the scheme, including whether it is a scheme with or without rights accrual based on the economic reality of the scheme.
  • If an obligation is recognized, the discount rate used and other key assumptions and bases.
Early retirement schemes
For early retirement schemes, the following changes/clarifications apply:
  • A definition of an early retirement scheme has been included.
  • It's addressed when an obligation is recognized and how that obligation is valued, with 2 possibilities:
    • For employees who are already using or can use the scheme at the balance sheet date: the obligation is the present value of the total expected expenses for those employees.
    • For employees who can't yet use the scheme at the balance sheet date but can do so during the term of the scheme in the future: an obligation will be accrued over the period in which the right to benefits is essentially accrued.
Expected expenses are allocated proportionally to the accrual period, meaning the obligation relates to the time-proportional part of the present value of the total expected expenses for those employees. Performance and disclosure requirements are included. The required disclosures cover the main characteristics of the schemes, the discount rates used, and other key assumptions and bases.
Impact of the Future Pensions Act on DAS 271
This change updates the definitions and terms without making substantive changes. Some provisions are excluded because they are no longer relevant in the new context, such as:
  • Claims for future refunds due to, for example, coverage ratio.
  • Obligations due to recovery premiums payable to the pension provider
However, some provisions regarding situations that can no longer occur under the Future Pensions Act haven't been removed.
Example:
  • Obligations to the pension provider due to indexation may arise, including after January 1, 2028, particularly with foreign pension schemes.
  • An example shows that compensation measures from transitional schemes can create an additional obligation to the pension provider.
Adjustment of the guidance for the application of IAS 19R in the Dutch pension situation as a result of the Future Pensions Act
The Dutch Accounting Standards Board (DASB) has outlined the impact of the Future Pensions Act (WTP) on applying the Guidance for the Application of IAS 19R in the Dutch pension context. Since this guidance will become less relevant under the WTP, the DASB plans to withdraw it by the end of the transition period for the WTP introduction on January 1, 2028. Pension schemes that comply with the WTP will generally be classified as defined contribution schemes under IAS 19R. However, factual obligations, such as those arising from employer-created expectations, may affect the scheme's classification.
The DASB believes that IAS 19R provides sufficient points of reference for assessing such factual obligations.
Draft Guideline DAS 214 “Financial Fixed Assets”
The DASB has revised Guideline 214 Financial Fixed Assets to enhance the accessibility of the Guidelines for Annual Reporting. They’ve adjusted the structure, added more headings, and removed some paragraphs that duplicated content in Guideline 214. These adjustments don't intend to make substantive changes.
Replacement of “Framework for the Preparation and Presentation of Financial Statements”
The DASB proposes to abolish the “
Framework for the Preparation and Presentation of Financial Statements
”, which is included as an appendix to the DAS bundle with Guidelines for Annual Reporting. At the same time, the DASB proposes to retain some important provisions from the Framework by including them in Section 1 “
General Principles
”. In addition, the DASB proposes to include certain conceptual principles underlying the preparation and presentation of (Guidelines for) annual reporting in the DAS bundle in a new introductory general paragraph entitled “
Background and Principles of the Guidelines
”. The proposed adjustments don't intend to make substantive changes and the conceptual principles of the Guidelines remain unchanged.
Country-by-Country Reporting – Adjustment of Chapter 500 due to “Profit Tax Disclosure Report”
The EU Directive on Profit Tax Disclosure (Directive EU/2021/2101) was implemented in Dutch law in 2024. The purpose of this legislation is to promote transparency of profit tax payments worldwide by large multinationals. As a result, large multinationals with more than €750 million (consolidated) net turnover or income are required to prepare and publish an annual profit tax report.
Section 5, "
Country-by-Country Reporting
," is part of the DAS bundle, along with Chapter 500, "
Country Information
." Due to recent legislative changes, it is proposed to specify in separate paragraphs within Chapter 500 which companies the country-by-country reporting legislation applies to.
This concerns:
  • Certain companies active in the extractive industry or logging of primary forests (paragraph 500.2).
  • Banks or investment firms (paragraph 500.3).
  • Large multinationals with a net turnover of more than €750 million.
In 3 separate paragraphs, the different forms of country-by-country reporting are then explained.
Full text of the new
D AS 500 Country-by-Country
reporting below for reference:
500 Country-by-country reporting
This Standard 500 (revised 2024) replaces Standard 500 (2017) and applies to reporting periods beginning on or after January 1, 2025.
500.1 Introduction
Object and scope
500.101
This chapter deals with the requirements for country-by-country reporting, also known as country reporting, as part of the annual reporting of companies. The country-by-country report is a report that is drawn up and published separately from the financial statements, the management board report, and other information.
500.102
This chapter describes the legal requirements regarding the content of the ‘country-by-country report’. The legal requirements for country-by-country reporting apply exclusively to specific categories of companies. This chapter sets out the different forms of country-by-country reporting in 3 separate paragraphs.
Paragraph 2 contains the requirements for country-by-country reporting by a large legal entity, public interest entity or issuing institution that is active in the extractive industry or in the logging of primary forests.
Paragraph 3 contains the requirements for country-by-country reporting by a bank or investment firm.
Paragraph 4 contains the requirements for country-by-country reporting by multinational companies or groups with a (consolidated) net turnover of more than €750 million.
Paragraphs 2 to 4 summarise the legal requirements for country-by-country reporting as included in the relevant general administrative order for which article 2:391a of the DCC forms the legal basis.
500.2 Country reporting on extractive industry activities and logging of primary forests
500.201
The provisions for a ‘country-by-country report’, being a ‘report of payments to governments’, follow from the Decree on reporting payments to governments (Staatsblad 2015, no. 439), which is included in Standard 910, paragraph 15a Formats and decrees (hereinafter: Decree on reporting payments to governments).
500.202
The Decree on reporting payments to governments applies to large legal entities, public interest organisations and issuing institutions that are active in the extractive industry (in particular oil, natural gas or minerals) or in the logging of primary forests (article 2 Decree on reporting payments to governments).
This concerns:
  • A large legal entity: a legal entity that hasn’t met at least 2 of the 3 requirements referred to in article 2:397 (1) and (2) of the DCC on 2 consecutive balance sheet dates, without interruption thereafter on 2 consecutive balance sheet dates.
  • A public interest organisation: a legal entity as referred to in article 2:398 (7) of the DCC.
  • An issuing institution: an institution as referred to in article 5:25e Wft.
(Article 1 Decree on reporting payments to governments)
They must annually draw up and publish a ‘country-by-country report’, namely a ‘report on payments to governments’ of the countries – inside and outside the EU – in which they operate
(article 3 Decree on reporting payments to governments)
.
500.203
The report on payments to governments shall include, except where the payment in a financial year is less than €100,000, the following payments resulting from extractive or logging activities and made to national, regional, or local governments
(Article 1(c) of the Decree on payments to governments)
:
  1. Production rights
  2. Taxes
  3. Royalties
  4. Dividends
  5. Signing, exploration, and production bonuses
  6. License fees, rents, entry fees, and other fees for licenses or concessions
  7. Payments for structural improvements
With regard to the extractive or logging activities, the following information shall be included in the report on payments to governments for the financial year concerned:
  1. The total amount of payments made to each government
  2. The total amount per type of payment as mentioned above under 1 to 7, made to each government
  3. In the event that these payments are allocated to a specific project, the total amount per type of payment as mentioned above under 1 to 7, made for each such project, and the total amount of payments for each such project
(Article 4 paragraph 2 Decree on reporting of payments to governments)
500.204
If the company, as mentioned above in paragraph 202, is at the head of a group
(pursuant to article 2:406 of the DCC)
, a consolidated report is drawn up of payments to governments resulting from extraction and logging activities
(article 5 paragraph 1 Decree on reporting payments to governments)
.
There is an exemption for drawing up a consolidated report on payments to governments if:
  • Upon consolidation, the boundaries of the small legal entity
    (article 2:396 of the DCC)
    are not exceeded and no public interest organisation or issuing institution is part of the group
  • There is a group part of which the payments to governments are included in a consolidated report of a larger whole drawn up by a legal entity (parent company) falling under the law of an EU Member State
    (article 5 paragraph 2 Decree on reporting payments to governments)
The inclusion of information in the consolidated report on payments to governments is not required if (a) there is a significant and long-term restriction on the exercise of rights in respect of the assets or management, or (b) in very exceptional cases where the information can't be obtained without disproportionate costs or undue delay (article 5, paragraphs 2 and 3, of the Decree on reporting on payments to governments).
500.205
The (consolidated) report of payments to governments must be published annually within 12 months after the end of the financial year in the manner referred to in article 2:394, 1st paragraph, 2nd sentence of the DCC (article 3 Decree on reporting of payments to governments).
Issuing institutions must also keep this report of payments to governments publicly available for a period 10 years
(article 5:25e of the Financial Supervision Act (Wft)
.
500.206
The (consolidated) report on payments to governments doesn’t need to be audited by an external accountant (explanatory memorandum to article 3, Explanatory Memorandum, Decree on reporting of payments to governments).
500.3 Country-by-country reporting activities by a bank or investment firm
500.301
Provisions for a ‘country-by-country report’, namely ‘reporting by country’ follow from the Capital Requirements Directive Publication Obligations Implementation Decree (Staatsblad 2014, no. 334), which is included in Standard 910 section 15b Formats and Decrees (hereinafter: Capital Requirements Directive Publication Obligations Implementation Decree).
500.302
The Capital Requirements Directive Disclosure Obligations Decree applies to banks (as referred to in article 1:1 Wft) and certain investment firms with their registered office in the Netherlands
(Article 1 and 2 Capital Requirements Directive Disclosure Obligations Decree)
.
They must annually prepare a consolidated country-by-country report for each country in which they or their subsidiaries have an establishment
(Article 3 Capital Requirements Directive Disclosure Obligations Decree)
.
500.303
Country reporting includes the following information for each country:
  1. Name, nature of business, and geographical location of the company, its subsidiaries, and branches
  2. Turnover
  3. The average number of employees
  4. The profit or loss before tax
  5. The tax on profit or loss
  6. The government grants received
(Article 3(1) Decree implementing publication requirements of the Capital Requirements Directive)
The information mentioned above under b to f, is based on the same methods and principles applied for the financial statements (explanatory note to Article 3, Explanatory note, Decree implementing publication requirements Capital Requirements Directive).
500.304
If possible, the (consolidated) country report shall be made public at the same time as the (consolidated) financial statements. If the (consolidated) country report is not included in the (consolidated) financial statements, the company shall disclose where and when the information can be found
(Article 3(3) Decree Implementing Publication Requirements Capital Requirements Directive)
.
500.305
The (consolidated) country report must be audited by an external auditor authorised to audit the (consolidated) financial statements
(Article 3(2) Decree Implementing Publication Obligations Capital Requirements Directive)
.
500.4 Country reporting income taxes paid by country by multinational companies or groups with (consolidated) net sales or revenues exceeding €750 million
500.401
The provisions for a ‘profit tax information report’ follow from the Implementation Decree on the Directive on Disclosure of Profits Tax (Staatsblad 2024, No 43), which is included in Standard 910 section 15c Formats and Decrees (hereinafter: Implementation Decree on the Directive on Disclosure of Profits Tax).
500.402
The Disclosure of Profits Tax Directive Implementation Decree applies to:
  • A public limited company or private limited company, or a partnership or limited partnership, of which all partners are fully liable to creditors for the debts referred to in
    Article 2:361 (2) of the DCC
    , which:
  • Independently or as the ultimate parent company has achieved a (consolidated) net turnover, as referred to in Article 2:377 (6) of the DCC, of more than €750 million for 2 consecutive reporting years.
If and insofar as
Article 2:377 (6) of the DCC
doesn't apply, the above limit of €750 million is determined on the basis of the revenue achieved according to the reporting system applied in the financial statements
(Articles 1 and 2 Implementing Decree on the Disclosure of Profits Tax Directive)
.
500.403
The Implementation Decree Directive on Disclosure of Profits Tax doesn’t apply to a company or ultimate parent company that is a bank or investment firm and prepares and discloses a country-by-country report, as described in paragraphs 302 and 303
(Article 2(3) Implementation Decree Directive on Disclosure of Profits Tax)
.
The Disclosure of Profits Tax Directive Implementation Decree also doesn’t apply to a company and ultimate parent company, as mentioned in paragraph 402, which is exclusively domiciled in and has business activities in Dutch territory
(Article 2(2) Disclosure of Profits Tax Directive Implementation Decree)
.
500.404
The profit tax report contains the following information:
  1. The name of the company or ultimate parent company, the reporting year involved, the currency used and, if applicable, the list of all subsidiaries included in the consolidated financial statements
  2. A brief description of the nature of the business
  3. The average number of employees
  4. Its revenues, which are calculated as:
    1. The sum of net turnover, other operating income, result from participating interests (excluding dividends received from group companies), income from other securities and receivables, other interest income and similar income as referred to in article 2:377 of the DCC
    2. The income calculated in accordance with the reporting system on the basis of which the financial statements are prepared, excluding value adjustments and dividends received from group companies
  5. The amount of profit or loss before income tax
  6. The amount of profit tax attributable during the financial year, to be calculated as the current year’s tax expense in the relevant tax jurisdiction. This tax expense relates only to the activities in the relevant financial year and doesn’t include deferred taxes or provisions for uncertain tax liabilities
  7. The amount of income tax paid (on a cash basis) during the financial year in the relevant tax jurisdiction
  8. The amount of accumulated profit at the end of the financial year, where accumulated profit means the sum of profits of the financial year and previous financial years for which it hasn’t been decided to distribute
(Article 7(2), (3) and (4) Implementation Decree Directive on disclosure of profit tax)
Certain information mentioned above may be omitted from the profit tax report if its disclosure would be particularly detrimental to the competitive position of the company to which the information relates. Such omitted information shall be disclosed in another profit tax report no later than 5 years from the date of the original omission
(Article 9(1) and (2) Implementation Decree Directive on disclosure of profit tax)
.
500.405
The income tax report shows separately the information:
  • For each EU member state and country affiliated to the EEA (European Economic Area)
  • For each jurisdiction designated by the Minister for Legal Protection as a non-cooperative or cooperative jurisdiction for tax purposes
    (Article 8(1) Implementation Decree on the Profit Tax Disclosure Directive)
For other tax jurisdictions, the information is presented on an aggregate basis
(Article 8(1) Implementation Decree Directive Disclosure of Profits Tax)
.
500.406
The company or ultimate parent company referred to in paragraph 402, or a subsidiary or branch
(Articles 3 and 4 Implementing Decree)
, shall prepare an annual profit tax report. In the case of a subsidiary or branch, the profit tax report shall state the name and address of the head office in an EU Member State or country affiliated to the European Economic Area
(Article 5(2) Implementation Decree Directive on disclosure of profit tax)
.
The profit tax report shall be drawn up in the currency in which the (consolidated) annual accounts are disclosed
(Article 10(1) Implementation Decree Directive on Disclosure of Profits Tax)
.
500.407
The profit tax report shall be made public, no later than 12 months after the end of the financial year, by filing it with the trade register as referred to in Article 2:394 of the DCC
(Article 11(1) Implementation Decree Directive on disclosure of profit tax)
.
The profit tax report shall be made public, free of charge and in an electronic format, on the website of the company, subsidiary, group company, branch, or ultimate parent company
(Article 11(2) Implementation Decree Directive on disclosure of profit tax)
.
The profit tax report shall be accessible on the website for at least 5 years
(Article 11(3) Implementation Decree Directive on disclosure of profit tax)
.
500.408
The (consolidated) profit tax report need not be audited by an external auditor. The external auditor who has audited the annual accounts of the legal entity shall state in the audit report, as referred to in
Article 2:393(5) of the DCC
, whether, with respect to the financial year preceding the reporting year for which the audited financial statements have been prepared, the legal entity was required to disclose a profit tax report and, if so, whether the report has been disclosed
(Article 12 Implementation Decree Directive on disclosure of profit tax)
.
What are the local accounting law changes for the upcoming December 2025 financial year?
Proposal for digital filing by large legal entities
Micro, small, and medium-sized legal entities already digitally file their annual accounts using Standard Business Reporting (SBR). Authorities granted large legal entities a postponement for mandatory electronic filing of their annual reports via SBR because these entities often align their reporting with listed companies. Therefore, it was logical to synchronize the obligation for large legal entities with that of listed companies. The European Single Electronic Format (ESEF) is now introduced for issuers, who must file their annual accounts in this format starting from the 2021 financial year. Authorities expect to mandate digital filing via SBR for large legal entities beginning in the 2025 financial year, with the decision's publication anticipated by the end of 2024.
Is early adoption available for these accounting standards?
New DAS guidelines may be adopted earlier. If adopted earlier a new standard may only be applied as a whole.

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