RJ 272: taxes on profit and deferred taxes

The short answer

RJ 272 governs taxes on profit in Dutch annual accounts. You recognise the tax due for the year, plus deferred taxes for temporary differences between commercial and tax carrying amounts: a deferred liability in principle always, a deferred asset only if offsetting is probable. Permanent differences, such as the participation exemption, give no deferred tax. Micro and small entities follow RJk B15.

Updated 30 October 2026

Key facts

Current tax and deferred tax

Current tax is what you still have to pay or will receive for the financial year and earlier years (RJ 272.201). A tax loss that you carry back to a prior year gives rise to a receivable immediately (RJ 272.202).

Deferred tax arises because the tax authority values an item differently from the annual accounts. If an asset is worth more commercially than for tax, or a liability is higher for tax than commercially, you pay more tax later: a taxable temporary difference, which you recognise as a deferred tax liability under provisions (RJ 272.301). The reverse, a deductible temporary difference, gives rise to a deferred tax asset, but only to the extent that sufficient taxable profit will probably be available to offset it (RJ 272.306 and 272.308). The same applies to losses not yet offset, with the caveat that a series of losses is itself an indication that this profit will not come (RJ 272.311 and 272.312).

Permanent differences give no deferred tax. A fine that is not tax deductible or a dividend under the participation exemption only changes the tax burden for the year (RJ 272.104 and 272.316).

Exceptions and special cases

• Initial recognition. An asset or liability that you recognise outside an acquisition, with no effect on the commercial and tax result and without equal taxable and deductible differences, may be recognised without deferred tax (RJ 272.301a and 306a; RJk B15.105 and 106). This exception comes from RJ-Uiting 2025-2 and is included in the editions from financial year 2026.
• Participations. For retained profits of a subsidiary you recognise no deferred liability if you determine when it is distributed and that distribution is not foreseeable (RJ 272.316).
• Revaluation. The law does not force a deferred tax on revaluation, but the Council (Raad voor de Jaarverslaggeving) strongly prefers it (RJ 272.304; art. 2:390(5) DCC).
• Pillar Two. For the minimum tax on large international groups you never recognise deferred taxes; you explain the charge and how it is accounted for (RJ 272.102a and 272.717).

Rate, uncertain positions and present value

You value deferred taxes at the rate that applies in the years in which the difference reverses, as far as it is established or materially enacted at the balance sheet date (RJ 272.401). With corporate income tax in two brackets, you take the average rate you expect in those years (RJ 272.402): a BV that structurally stays below € 200,000 of taxable profit uses 19%. How you intend to realise an asset also counts: selling or using it can lead to a different rate (RJ 272.403).

If you take a position in the tax return that the Dutch Tax Administration is not probable to accept, you value the tax position at the best estimate of what you will ultimately pay (RJ 272.402a). You may value deferred taxes nominally or at present value; discounting uses the net interest rate, that is, the interest on long-term loans after tax (RJ 272.404 and 272.405). Every year you reassess whether a deferred tax asset can still be realised (RJ 272.406).

Case: reinvestment reserve and a fine

Kraanverhuur Delta BV sells an old aerial work platform in 2025 with a book gain of € 50,000. It is going to buy a new one and reserves the gain for tax in a reinvestment reserve; commercially the book gain is simply in the result. The result before tax is € 150,000; this also includes a fine of € 5,000 that is not tax deductible. The BV expects to stay below € 200,000 of taxable profit in the coming years as well.

The reconciliation: 19% of € 150.000 is € 28.500, plus 19% on the non-deductible fine (€ 950), is € 29.450. The effective tax rate is € 29.450 / € 150.000 = 19,6%, against an applicable rate of 19%. The journal entry: Taxes € 29.450 to Corporate income tax payable € 19.950 and Provision for deferred taxes € 9.500. Once the new platform is there, the reserve is deducted from its tax cost; the BV then depreciates less for tax than commercially and the deferred tax is released gradually.

As a small BV, Delta is sufficiently served by the basis for the deferred taxes in the notes (RJk B15.121). Had it been medium-sized, it would have included the reconciliation above, with the effective and the applicable rate (RJ 272.703 and 272.704). If, as a small BV, it applies tax bases (art. 2:396(6) DCC), the annual accounts follow the tax values, with the reinvestment reserve shown separately in equity, and the deferred tax lapses.

Case: loss in the first year

Lumen Analytics BV starts in 2025 and closes the year with a tax and commercial loss of € 80.000. For 2026 it has signed contracts with three customers that comfortably cover the costs. Because offsetting the loss is probable, it recognises a deferred tax asset of 19% × € 80.000 = € 15.200. The result after tax becomes − € 80.000 + € 15.200 = − € 64.800. Had Lumen already had three loss-making years behind it with no concrete prospect of profit, the asset would not be recognised; a medium-sized or large entity then discloses the unrecognised losses in the notes (RJ 272.710).

Fiscal unity: who recognises the tax?

In a fiscal unity (fiscale eenheid) only the parent is liable to tax. How the charge is allocated to the subsidiaries follows from the agreement within the group. The Guidelines know four variants: settling as if the subsidiary were independently liable to tax, settling on the taxable profit with distribution of the benefits, settling on the commercial profit, or the parent bears everything (RJ 272.803). In the first two, the subsidiary recognises tax and deferred taxes, as a receivable or liability on the parent; in the third the charge but no deferred taxes; in the fourth the subsidiary explains why its annual accounts contain no tax (RJ 272.804). It is advisable to put the agreement in writing (RJ 272.803); also disclose the joint and several liability of the companies in the unity for the tax debt (RJ 272.808). More at fiscal unity.

What differs per financial year

Per size class

Common mistakes

• Recognising a deferred tax asset on losses without support for future profit.
• Using the 25.8% rate while the BV stays in the first bracket in the years of reversal.
• Recognising deferred taxes alongside tax bases.
• Recognising a deferred tax on a participation that falls under the participation exemption.
• In the fiscal unity, showing deferred taxes at the subsidiary while the agreement settles on the commercial profit.

How it works in Jaarrekening.io

Jaarrekening.io asks a medium-sized or large entity in the notes about deferred taxes and about the reconciliation of the tax burden. If a micro or small entity chooses tax bases and there is still a provision for taxes on the balance sheet, or a small entity also chooses deferred taxes, the app warns you. The calculation of the tax itself remains your work or that of your adviser.

Sources

• Art. 2:374 DCC: provisions, including for tax liabilities (wetten.overheid.nl)
• Art. 2:396 DCC: small entities and tax bases
• RJ-Uiting 2025-2: deferred taxes on initial recognition of assets and liabilities (rjnet.nl)
• Dutch Tax Administration (Belastingdienst): corporate income tax rates
• Dutch Accounting Standards Board (Raad voor de Jaarverslaggeving): the Guidelines and the compilations (rjnet.nl)
• Dutch Accounting Standards Board: Ten geleides per annual edition, with the changes per financial year

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