{"type":"document","data":{"id":"0fb6143a-262a-4f4b-8403-add4daf444ed","localeString":"en-GB","publishDate":"2025-11-06T18:00:25.888+01:00","contentType":"onecms:productPage","hasMacro":false,"flexPageMetadata":{"afmBanner":false,"robotInstruction":{"noIndex":false,"noFollow":false},"description":"Read more about the latest developments in the Business Succession Scheme (BOR). Discuss your options with our experts."},"mainHeaderZone":{"componentType":"productHeader","coreHeader":{"body":"Planning to transfer your business to the next generation with peace of mind? Then it is essential to stay informed about the latest changes to the Dutch business succession tax facilities known as ‘bedrijfsopvolgingsregeling’ (BOR) and the deferral scheme or ‘doorschuifregeling’ (DSR).","headerImage":{"transformBaseUrl":"https://assets.ing.com/transform/3da0809a-5aa5-4b19-866f-ad50ea78b2bb/686820643","type":"image","width":4032,"altTextNL":"\"\"","original":"https://assets.ing.com/m/6853cc1141071a3e/original/686820643.jpg","extension":"jpg"},"title":"The new Dutch business succession rules – How to prepare in a tax-efficient manner"},"backLink":{"textLink":{"url":"/en/private-banking/knowledge-and-insights/entrepreneurship","text":"Entrepreneurship"}}},"flexZone":{"flexComponents":[{"componentType":"paragraph","richBody":{"value":"<p>Recent and upcoming reforms could significantly impact your succession strategy. For instance, BOR and DSR can no longer be applied to rented real estate. Below, we outline the key developments and actions for 2025 and 2026.</p>"}},{"componentType":"sectionTitle","title":"What has changed as of 1 January 2025?"},{"componentType":"paragraph","richBody":{"value":"<p>You can transfer your business more easily. Smaller businesses benefit from a higher exemption. </p><ul><li><p>Higher exemption threshold. Benefit from a full exemption on the first €1.5 million of business assets. Above that, a 75% exemption applies (previously €1.2 million and 83%). </p></li></ul><ul><li><p>‘Doelmatigheidsmarge’ for the BOR abolished. Previously, this provision allowed up to 5% of a company’s assets classified as investment capital to still qualify as business assets for the purposes of the BOR. As of 1 January, this benefit was abolished. </p></li></ul><ul><li><p>Shorter continuation requirement: you now only need to continue the business for 3 years to qualify for BOR (previously 5 years), offering greater flexibility in succession planning. </p></li></ul><ul><li><p>No employment requirement under DSR: you are no longer required to have been employed for at least three years to benefit from the deferral scheme. </p></li></ul><ul><li><p>Minimum age for gifts: the successor must be at least 21 years old to qualify for BOR and DSR in case of a gift. </p></li></ul><ul><li><p>Rules for mixed-use assets: if a business asset worth €100,000 or more is used at least 90% for business purposes it fully qualifies as business assets. Less than 10% business use? It’s considered private. Anything in between is proportionally allocated. </p></li></ul>"}},{"componentType":"sectionTitle","title":"What to expect from 1 January 2026?"},{"componentType":"paragraph","richBody":{"value":"<p>Abuse is being tackled, and businesses are granted greater flexibility to restructure.</p><ul><li>Stricter holding requirements for late succession (‘rollator investment’). If you acquired the business more than two years after reaching the state pension (AOW) age a longer holding period will apply before the BOR can be used. The older you were at acquisition the longer the required holding period. Consult your tax advisor to determine which timeline applies to your situation. </li><li><p>Avoid the ‘BOR carousel’. If you’ve previously owned part of the business, you cannot reapply the BOR to that same portion. </p></li></ul><ul><li><p>Reduced risk during restructuring. Planning a merger or demerger? The holding or continuation period will not restart, provided ownership rights remain unchanged. This allows for strategic growth or succession planning.</p></li></ul>"}},{"componentType":"sectionTitle","title":"More information about BOR and DSR "},{"componentType":"paragraph","richBody":{"value":"<p>Want to know how these changes might affect your situation? Consult your tax advisor. ING Private Banking’s experts are ready to support you: whether it is structuring your financing or optimizing your investments. Contact us for tailored advice aligned with your goals and ambitions. </p><p>Written by Stef Goossens, Tax Expertise Manager.</p>"}},{"componentType":"accordion","accordionList":[{"title":"Based on the situation as of August 7, 2025","richBody":{"value":"<p>The information provided by ING in this article is not an offer, advice, or financial service and is solely intended to inform you and provide practical tips. We always recommend consulting a specialist regarding your financial and/or wealth planning. This article has been compiled with the utmost care. However, it may contain inaccuracies or omissions. ING is not liable for any damage (of any kind) resulting from the use of the information provided. No rights can be derived from the information. Any rates mentioned are indicative and not binding for ING. All rights and changes reserved. This is a publication of ING Bank NV, registered in Amsterdam.</p>"}}]}]},"complementaryZone":{"flexComponents":[{"componentType":"cards","cards":[{"componentType":"productCard","cardType":"product","cardSize":"small","title":"Make an appointment","intro":"Let's start a conversation.","image":{"transformBaseUrl":"https://assets.ing.com/transform/3e538078-976f-4b74-b49c-90d7cd895df2/Web-12","type":"image","width":307,"original":"https://assets.ing.com/m/1d41bac33a10b194/original/Web-12.svg","extension":"svg"},"link":{"url":"/en/private-banking/customer-service"}},{"componentType":"productCard","cardType":"product","cardSize":"small","title":"Log in to My ING","intro":"Quick insights into your financial situation","image":{"transformBaseUrl":"https://assets.ing.com/transform/33c4e3a2-7e3d-47a1-9c6f-1993eedcdb8c/Web-13","type":"image","width":307,"original":"https://assets.ing.com/m/5aecfb619a645cd6/original/Web-13.svg","extension":"svg"},"link":{"url":"https://mijn.ing.nl/login"}}]}]}}}