Version 25 - March 2026 (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, 2026.
- Financial Period Type: 12-Months (Annual)
- Target Industry Type: Manufacturing, Services, and Generic (excluding Financial Services).
Legislative updates
Local accounting law changes for the upcoming December 2026 financial year
1. Deferred taxes on the initial recognition of certain assets and/or liabilities
DAS (Dutch Accounting Standards) Statement 2025-2 is relevant for an entity that acquires an asset and/or liability in a transaction where the purchase price differs from the tax-deductible amount, and the transaction doesn't qualify as a business combination under DAS 216 “Mergers and Acquisitions”.
Examples include transactions where the shares of a company are acquired and that the company holds only 1 or a limited number of assets, without constituting an integrated set of activities, assets, and/or liabilities capable of generating revenue. For tax purposes, the historical tax book value is generally maintained, and the excess paid for the shares is not tax-deductible.
Under IFRS (IAS 12.15 and IAS 12.24), there is a mandatory exception for recognizing deferred taxes on temporary differences in certain situations (referred to as the “initial recognition exception” or IRE). In the Dutch Accounting Standards, a similar exception can be inferred from paragraph 104 (“Differences that don't give rise to deferred tax”).
The DAS now proposes to explicitly include this exception in DAS 272 “Income Taxes,” but not to make it mandatory. In other words, it will still be permitted to recognize deferred taxes for such temporary differences, provided these will result in payable or recoverable taxes in future periods upon realization or settlement of the asset or liability. The explanatory notes clarify that this will initially not affect profit or loss.
note
This change doesn't impact the statutory reporting model. The Dutch Accounting Standard Board has only given further clarification on the accounting treatment.
2. Financial statements prepared in accordance with EU-IFRS in combination with Title 9, Book 2 DCC (Dutch Civil Code)
This change is relevant for entities that prepare consolidated and/or company financial statements in accordance with EU-IFRS. In the current Dutch Accounting Standards, paragraphs that are supplementary to the application of EU-IFRS are included across various standards.
The DAS proposes to transfer all paragraphs that are supplementary to the application of EU-IFRS into a new Standard: 'DAS 105 Financial statements prepared in accordance with EU-IFRS in combination with Title 9, Book 2 DCC'.
In addition to this relocation to DAS 105, the DAS has refined 2 topics. These concern:
- Events after the balance sheet date; and
- Application of article 2:362(9) DCC
2.1 Events after the Balance Sheet Date
In the Dutch Accounting Standards, it's stated that an entity applying a combination 3 or 4 should only reflect the effects of events after the reporting date that becomes known up to the point when the financial statements are prepared ("date of authorization for issue"). It was explicitly stated that the effects of events identified after the preparation of the financial statements, even if they provide additional information about the actual situation at the reporting date, shouldn't be reflected; this required some clarification.
According to article 2:362(6) DCC, events identified after the preparation of the financial statements and before their adoption needs to be reflected in the financial statements to the extent necessary to provide a true and fair view. EU-IFRS doesn’t address the period between the preparation of the financial statements and their adoption. If such a situation arises, management may decide to reissue the financial statements, considering the effects of these events.
In addition, listed entities need to comply with the provisions of article 5:25c(7) of the Dutch Financial Supervision Act (Wft), which requires a listed entity to immediately publish an announcement if, after making the financial statements generally available but before their adoption, new facts or circumstances become known.
2.2 Application of article 2:362(9) DCC
Article 2:362(9) DCC declares certain articles and sections of Title 9, Book 2 DCC applicable when financial statements are prepared in accordance with EU-IFRS. This is particularly relevant when company-only financial statements are prepared under EU-IFRS or when both company-only and consolidated financial statements are prepared under EU-IFRS.
In practice, there are differing views on whether the disclosure requirement regarding the average number of employees (art. 2:382 DCC) also applies to consolidated financial statements prepared under EU-IFRS. The DAS is of the opinion that it does apply, as this disclosure requirement is relevant not only for company-only financial statements but also for consolidated financial statements; this has now been clarified in the Standards.
note
These changes don’t impact the statutory reporting model. The Dutch Accounting Standard Board has only given further clarification on the accounting treatment. More specifically these changes are only applicable to the situation that the company applies IFRS in combination with Title 9, Book 2 DCC.
3. Equity
As part of improving the accessibility of the Dutch Accounting Standards, DAS 240 Equity has been rewritten. In addition, clarification has been provided regarding the treatment of the repurchase of own shares. It has been clarified that the acquisition price or carrying number of repurchased shares is deducted from the distributable reserves or statutory reserves, provided that the articles of association allow this.
The wording of paragraph 214 in DAS 240 of the 2025 edition could give the impression that the acquisition price or carrying amount could also be deducted from the legal reserves, which is not permitted.
note
This change doesn’t impact the statutory reporting model. The Dutch Accounting Standard Board has only given further clarification on the accounting treatment.
Early Adoption of Accounting Standards
New DAS guidelines may be adopted earlier. If adopted earlier, a new standard may only be applied as a whole.