A founder can spend forty years building a company and still leave the hardest invoice to people who never signed a purchase order. I have seen that silence at family tables. The business looks healthy, the house has value, the shares look impressive, and the first question after death is painfully simple: where will the cash come from?
The 2026 picture is more useful than a rate headline. It is about exemptions, relationship-based rates, filing time, gifts shortly before death, biological-child treatment, and updated Belastingdienst positions under the Successiewet.
The rate table is only the front door
Belastingdienst figures for 2026 show how much the family relationship already matters. A partner has an exemption of €828,035. A child, foster child, stepchild or grandchild has an exemption of €26,230. Other heirs, such as a sibling or friend, have an exemption of €2,769.
After the exemption comes the rate table. The 2026 threshold is €158,669. Partners and children pay 10 percent up to that threshold and 20 percent above it. Grandchildren and further descendants pay 18 percent and 36 percent. Other heirs pay 30 percent and 40 percent.
Those numbers are tidy. The business reality is not. Imagine a small installation company in Brabant. The founder owns the BV shares, the workshop property, a rented apartment above it and a current-account position with the company. One child works in the business. Another has no role there. The partner needs income security.
On paper, the family may look well-off. In cash, it may be tight. That is where inheritance tax stops being a table and starts behaving like a balance sheet.
The longer calendar is a control window
For deaths on or after 1 January 2026, heirs have 20 months to file the inheritance-tax return. Tax interest starts only after 20 months if no complete return has been filed. That gives more room in estates with shares, property, loans or family claims.
I would not treat that period as spare time. It is a control window. Heirs still need to identify assets, collect valuations, check ownership, understand gifts, speak with the notary, speak with the adviser and decide how the tax will be paid.
The rule for gifts shortly before death also changed for deaths on or after 1 January 2026. Gifts made in the final 180 days are treated as part of the inheritance. A separate gift-tax return is no longer needed for those gifts.
That simplifies the route, but it does not erase the record. Money moved. Assets moved. The file still needs to explain when, to whom and why. In the Brabant example, that may mean housing help for one child, a family loan to another, or a share transfer made during illness.
BOR is relief with conditions
For founders, the business succession scheme, the BOR, is often the centre of the discussion. Belastingdienst guidance says the BOR may reduce or remove inheritance or gift tax when an active, ongoing business is inherited or gifted and continued. Investments do not fall under the BOR.
The conditions matter. For inheritance, the previous owner must have owned the business for at least one year. For gifts, the recipient must be at least 21 and the previous owner must have owned the business for five years. For acquisitions from 1 January 2025, the continuation period is three years.
That is why loose talk about protected family companies is dangerous. A BV is not a magic tax shelter. The question is what the company actually does, what assets it holds, who owned what, and whether the business continues in a way the rules recognise.
CPB has already kept pressure on this point. In its 2022 evaluation, CPB concluded that the BOR exemption was not efficient in many cases. It also reported that in about three quarters of transfers enough free financial resources were available at transferor, donor or recipient level to pay the tax directly.
Belastingdienst Kennisgroepen updated several Successiewet positions on 6 July 2026 because of legislative changes from 2025 and 2026, including BOR-related positions. For a family, those positions can matter in the specific share, claim, property, loan or continuation fact on the table.
Property can be valuable and cash-poor
CBS wealth figures help explain the background. In provisional 2024 figures published in 2026, average total wealth for homeowners was €563.8 thousand, compared with €40.4 thousand for renters. These are averages, not medians. Still, the signal is plain: Dutch wealth often sits in homes, not in spare bank balances.
For estates, that creates a familiar problem. A house, rented property or company building can carry value without producing the cash needed for tax. Belastingdienst guidance on rented or leased homes also shows that valuation is not always a simple WOZ copy. The leegwaarderatio can matter in certain cases. From 2026, it no longer applies in specified non-market rental situations between related parties.
Then box 3 enters the room. For 2026 provisional assessments, Belastingdienst uses 1.28 percent for bank balances, 6.00 percent for investments and other assets, and 2.70 percent for debts. The box 3 tax rate is 36 percent. Belastingdienst also states that inheritance tax can be a box 3 debt.
So the estate does not live in one tax silo. Inherited savings, investments, second homes, rented property, claims and debts can all affect the next income-tax position of the heirs.
The practical test
For the founder in Brabant, the useful conversation is not whether inheritance tax may one day become heavier. It is whether the estate can be understood tomorrow morning.
Which assets belong privately, and which belong to the BV? Which child receives what? Which values can be defended? Which relief is being assumed? Which cash route avoids damaging the company? A longer filing period helps if the family uses it early. It does little for heirs who wait fifteen months before opening the accounts.
Inheritance tax is intimate because it arrives after loss. It is also technical because the tax authority cannot administer grief. It administers relationships, values, exemptions, conditions and dates.
That is the calm lesson from the 2026 Dutch changes. Founders have a wider calendar, not a lighter responsibility. The rate table is visible. The real work sits behind it, in the estate papers, the valuation, the business facts and the cash plan the family may one day need before it feels ready.
Need a check on valuation, BOR conditions, and the payment plan in your succession file? We can review the facts with you
The data, sourcing, and analysis behind this article were conducted by Linda Pavan. AI was not used to identify sources, build the factual basis, or produce the analytical judgment contained here. AI was used only as a drafting aid. The final English text was personally reviewed, edited, and approved by Linda Pavan before publication.
References
- Brede steun voor hogere belasting bij grote erfenissen - Taxence
- CPB - Older CPB baseline on inheritances, gifts, inequality, and tax pressure
- CPB - CPB evaluation of business succession relief
- CPB - Parental wealth and wealth mobility
- CBS - Current wealth distribution and estate asset base
- Belastingdienst - Inheritance tax exemptions for 2026
- Belastingdienst - Inheritance tax rates for 2026
- Rijksoverheid - Belastingplan 2026 inheritance and gift tax changes
