Mass Objection Procedure for Tax Interest on Income Tax (IB)

Objections Against Tax Interest on Income Tax 

From 8 May 2025, objections against tax interest on income tax (IB) assessments have been classified as mass objections. This classification also applies to other taxes, including wage tax and value-added tax (VAT). To be part of this process, you must ensure your objection is submitted on time. 
 

Tax Interest and the Principle of Proportionality 

On 7 November 2024, the District Court of North Netherlands determined that the tax interest calculated by the Dutch Tax and Customs Administration (Belastingdienst) on corporate income tax (Vpb) assessments violated the principle of proportionality. As a result of this ruling, a significant number of objections relating to tax interest have been submitted to the Belastingdienst. 
 

Classification as Mass Objection 

From 7 February 2025, objections against tax interest on corporate income tax (Vpb) assessments issued from 1 October 2020 onwards were categorised as mass objections. Initially, this did not cover objections against tax interest on income tax (IB). However, this changed on 8 May 2025. From that date, objections against tax interest charged from 1 October 2020 on IB, as well as on inheritance tax, wage tax, dividend tax, VAT, transfer tax, and BPM (motor vehicle tax), have also been classified as mass objections. 
 

What Does This Mean? 

This classification means that the Belastingdienst will not immediately issue individual decisions on these objections. Instead, it will temporarily suspend them. Once the relevant questions about tax interest have been definitively resolved through legal proceedings, the Belastingdienst will provide a single collective decision on all the objections. 
 

Submit Your Objection on Time! 

You are eligible to participate in this mass objection procedure. However, it is essential to submit your objection within six weeks of the date on the assessment. 

Important: 
Do not wait for court rulings before acting. If you receive an assessment with tax interest, you must take action. 
 

Decision on Objection Before 7 May or 7 February 2025? 

If you submitted an objection and the Belastingdienst issued a decision on it before 7 May 2025, you are not covered by the mass objection procedure. In this situation, you must file an appeal with the court to protect your rights. This condition applies to income tax (IB) and other taxes, including inheritance tax, wage tax, dividend tax, VAT, transfer tax, and BPM. 

Important: 
For tax interest on a corporate income tax (Vpb) assessment, you are excluded from the mass objection procedure if the Belastingdienst issued a decision before 7 February 2025. 
 

Different Procedure for Provisional Assessments 

A separate procedure applies if tax interest is calculated on a provisional assessment, which is more complex. You cannot directly object to the tax interest on a provisional assessment. Instead, you must first request a revision of the provisional assessment. After the Belastingdienst rejects this request, you can then object to the rejection. If this objection is submitted on time, it will be included in the mass objection procedure. 

Important: 
You cannot rely solely on an objection against the final assessment that settles the provisional assessment. Tax interest calculated on the provisional assessment will not be included in that objection. Therefore, you must also request a revision of the provisional assessment and object to its rejection if necessary. 
 

Other Objections? 

If your objection also addresses matters other than tax interest, the Belastingdienst will issue a decision on those additional objections. If the Belastingdienst fully or partially rejects these other objections, you have the right to appeal against this decision in court. 
 

Need Assistance? 

If you have questions about your situation or are unsure of the steps you need to take, please contact one of our advisors. We are here to help.