Sustainability Insights for Tax & Legal | September 2026
Welcome to our Sustainability Insights for Tax & Legal, keeping you informed of the latest developments in the fast-moving world of Sustainability!
This Sustainability Tax & Legal round-up features:
1. Tax-related climate measures 2027 Tax Plan
2. Adjustments to the pseudo final levy on fossil-fuel company cars
3. Update subsidy program IKC ETS NL
4. Changes to the SPRILA subsidy scheme
5. EC has released an update of the PPWR FAQ
6. EU CBAM | Guidance for CBAM verifiers
7. EU CBAM | New guidance documents
8. KPMG's Global Credits, Grants and Incentives newsletter - Defence edition
9. Our Tax & Legal services | Sustainable value creation
Enjoy the Insights and please contact our Sustainability team for Tax and Legal, if you have any questions or feedback - we are happy to help you!
Merijn Betjes
1. Tax-related climate measures 2027 Tax Plan
Budget Day has come around again, and the Dutch government has presented its 2027 Tax Plan to the Lower House of Parliament. In conversation with Merijn Betjes, we highlight the key Budget Day measures and their implications in the landscape of energy and climate. Download overview.
2. Adjustments to the pseudo final levy on fossil-fuel company cars
Several amendments have been proposed to the previously adopted pseudo final levy on fossil-fuel company cars.
The adjustments are intended to address practical issues that have been identified. As of 1 January 2027, employers will be subject to a pseudo final levy of 12% of the list price of fossil-fuel passenger cars that are also made available to employees for private use. Commuting is regarded as private use for this purpose. The levy is payable by the employer and applies in addition to any additional tax liability for the employee’s private use. Transitional rules apply to passenger cars that were first made available before 1 January 2027. The objective of the measure remains unchanged: to encourage employers to accelerate the transition to fully zero-emission vehicles.
Adjustments
• Exception for replacement vehicles: if an employee temporarily uses a replacement non-zero-emission vehicle due to damage, maintenance, repair, or a tire change, no pseudo final levy applies to that replacement vehicle for a period of up to fourteen consecutive days. This prevents temporary replacement transport from unintentionally resulting in (double) taxation.
• Extension of the transitional rules: for non-zero-emission vehicles that were already made available by the same employer before 1 January 2027, the transitional period is extended from 17 September 2030 to 1 January 2031. Ending the transitional period midway through a month during the calendar year would create additional administrative burdens.
• Temporary exemption for short-term use: once per calendar year, a fossil-fuel passenger car may be made available for up to seven consecutive days without the application of the pseudo final levy. This measure is intended primarily for the incidental use of rental or shared vehicles and will expire on 1 January 2031.
• Exemption for driving school vehicles: driving school vehicles with a manual transmission are exempt from the pseudo final levy. The government considers it undesirable for driving schools to be discouraged from using vehicles with manual gearboxes for instruction purposes.
Anti-cumulation provision
To prevent double taxation, a statutory anti-cumulation provision will be introduced. This concerns situations in which both the pseudo final levy on fossil-fuel company cars and the pseudo final levy on excessive severance payments would apply. Without such an anti-cumulation provision, double taxation could arise in certain cases for the same (legal) person on the same tax base.
3. Update subsidy program IKC ETS NL
In line with earlier communications from the European Commission, the Netherlands has updated the subsidy program Indirect Cost Compensation scheme EU ETS (IKC ETS). The scheme compensates energy-intensive companies for part of the increased electricity costs resulting from the EU Emissions Trading System (EU ETS). The scope of eligible sectors has been significantly broadened, allowing more industries to benefit from support. The Netherlands faces the challenge of both decarbonizing industry and maintaining its competitiveness, with electrification playing a key role in achieving these objectives.
Compared with last year, the list of eligible sectors has been substantially expanded. Producers of fertilizers, ceramic tiles, flat and hollow glass, stone wool, and organic basic chemicals are now eligible for compensation. Sectors such as aluminium, iron, paper, hydrogen and zinc also remain within the scope of the scheme.
Applications can be submitted as of today (the application window opened on 3 August 2026) and will remain open until 30 September 2026. The total available budget amounts to EUR 318 million. Companies applying under the scheme for the first time are expected to receive their subsidy in early 2027.
4. Changes to the SPRILA subsidy scheme
Are you an entrepreneur looking to install charging infrastructure for electric machinery or vehicles on your own or leased premises? The Private Charging Infrastructure at Businesses Subsidy Scheme (SPRILA) is available for this purpose. This scheme supports businesses in investing private charging points. Read more.
5. EC has released an update of the PPWR FAQ
Regulation (EU) 2025/40 establishes a harmonised legal framework for packaging and packaging waste across the European Union. Its primary objective is to ensure the smooth functioning of the internal market while significantly reducing the environmental and health impacts associated with packaging throughout its life cycle. Read more.
6. EU CBAM | Guidance for CBAM verifiers
Under CBAM, importers must submit annual declarations based either on actual verified emissions data or on default emissions values. In the case of actual emissions, the verification must be carried out by independent verifiers accredited by EU national accreditation bodies. This ensures the credibility, consistency and transparency of emissions reporting across the EU. Read more.
7. EU CBAM | New guidance documents
The European Commission has published a series of guidance documents to support CBAM implementation in the definitive period. The CBAM's definitive period brings monitoring, reporting and financial obligations for importers of carbon-intensive goods into the EU, set out in the CBAM Regulation and its secondary legislation. The guidance documents are aimed at a range of stakeholders, with a particular focus on operators of installations outside the EU that produce CBAM goods, as well as authorised CBAM declarants and verifiers involved in the compliance cycle.
Please find below four general guidance documents and six sector-specific guides:
- Guidance No. 1: Introduction to CBAM concepts: an introduction to the CBAM and its compliance cycle, roles and responsibilities, milestones, deadlines and exemptions for operators of installations outside the EU during the definitive period.
- Guidance No. 2: Quick guide for non-EU operators: a roadmap through the key concepts of CBAM emissions monitoring for operators of installations producing CBAM goods, pointing to where more detail can be found across the series.
- Guidance No. 3: Calculation of embedded emissions: the monitoring and reporting obligations and recommendations that may apply to any affected producer of CBAM goods.
- Guidance No. 4: Calculation of the free allocation adjustment: how the adjustment to the number of CBAM certificates to be surrendered for free allocation under the EU ETS is determined, and what information is needed.
- Guidance documents No. 5a–5f: Sector-specific guidance: dedicated overviews of production processes, value chains and monitoring and reporting considerations for each CBAM sector (cement, hydrogen, fertilisers, iron and steel, aluminium, electricity), each supplemented with worked examples.
- Guidance No. 5a - Sector-specific guidance document on cement
- Guidance No. 5b - Sector-specific guidance document on hydrogen
- Guidance No. 5c - Sector-specific guidance document on fertilisers
- Guidance No. 5d - Sector-specific guidance document on iron and steel
- Guidance No. 5e - Sector-specific guidance document on aluminium
- Guidance No. 5f - Sector-specific guidance document on electricity
Businesses need to ensure they are well prepared for the verification of their emissions data and have the right processes in place to report actual emissions. This set of resources will help importers to focus on to ensure using actual values for the 2026 imports, putting in place robust monitoring processes, understand the changes to the calculation of embedded emissions compared with the transitional period, how to use default values provided by the EC and understand how to apply the free allocation adjustment.
8. KPMG's Global Credits, Grants and Incentives newsletter - Defence edition
In this publication, we present an overview of the main sources of funding for the defence and dual-use sector, covering, among others, Poland, Germany, Spain, Portugal, the USA, and Canada. It is a practical introduction for organizations seeking opportunities to support research and development projects, industrial investments, and the scaling of innovative technologies. Download the newsletter.
9. Our Tax & Legal services | Sustainable value creation
From CGI and Carbon to Packaging, Energy and Reporting, our Sustainability Tax & Legal specialists help you navigate Sustainability requirements, manage risks and unlock opportunities for your business. Download overview of our services.
