On 28 February 2026, a new version of the Dutch decree explaining Table II of the VAT Act took effect (decree of 8 February 2026, no. 2026-1395, Stcrt. 2026, 6674). Table II lists the supplies and services that qualify for the zero rate. The decree replaces the version of 20 December 2023.
The main changes
Exports. The conditions for showing, through books and records, that the zero rate on exports applies have been clarified.
Intra-Community supplies. The decree no longer says that a supplier must demonstrate its due care in order to meet the burden of proof, as if that were a substantive requirement. This does not change the policy on due care, under which the zero rate can still be refused in certain circumstances.
Chain transactions. The term intermediary operator is clarified, following knowledge group position KG:210:2025:10.
Small businesses. The explanation of cross-border supplies by an exempt small business changes, in line with the Dutch law implementing the directive on the small business scheme.
Excise goods and VAT warehouses. For items a.7 and a.8, several conditions are no longer called formal conditions, but other conditions.
What to check
- The decree brings almost no change in policy, so existing processes can stay in place.
- Update your internal zero-rate instructions to the new text and terminology.
- Due care still matters in practice. Do not read the change on the burden of proof as a relaxation.
mr. J. el Khalfioui LL.M.