Can a foreign-owned company claim WBSO in the Netherlands?

Yes. WBSO does not look at who owns the company. It looks at who employs the people doing the research. A company established in the Netherlands that pays Dutch payroll tax for its research staff can apply, even when the parent company sits in Seoul, Tokyo or Singapore. The research itself has to take place inside the European Union.

Many founders assume a Dutch tax credit is only for Dutch companies. For WBSO, the Dutch tax credit for research and development, that is not how the rules work. This guide is for a founder whose company is registered outside Europe and who plans a Dutch subsidiary with its own engineers.

WBSO is run by RVO, the Netherlands Enterprise Agency. RVO calls the work S&O, the Dutch term for research and development. We use R&D here.

Does it matter that the parent company is foreign?

No. RVO lets any business established in the Netherlands apply for WBSO, except public knowledge institutions such as universities. The law describes the applicant as an employer that runs a business and withholds Dutch payroll tax. Ownership is not part of that test, so a Dutch company owned by a parent in Korea or Japan qualifies on the same terms as a Dutch-owned one.

What does matter is that the Dutch company runs the R&D itself. RVO expects the applicant to organise and carry out the work, also when it works together with another company or does the work for someone else. A Dutch company that only passes on a project from its parent, while the parent's engineers do the work, does not meet that test.

Sources:
RVO, Handleiding WBSO 2026, section 1.2
WVA, article 1, definition of S&O-inhoudingsplichtige

Whose hours count?

Only the hours of people on the payroll of the Dutch company that applies. WBSO pays out as a reduction of the payroll tax that company pays, so there has to be Dutch payroll to reduce. Engineers who stay employed by the parent company abroad do not count for the Dutch company, even when they work on the Dutch project.

This is the point where most foreign groups have to decide how to employ their team. Three rules from RVO settle most cases:

• Every company that has R&D staff on its own payroll applies for itself. A holding company and its operating company each apply separately.
• If one company lends its staff to another company for R&D, the employer applies, provided its own staff organise the work.
• Interns count only when they have a real employment contract.

RVO checks this afterwards. Hours registered for people who are not on the applicant's payroll are one of the reasons it gives for correcting a WBSO decision.

Source: RVO, Handleiding WBSO 2026, section 1.2.1, appendix A and section 7.2

Can the research happen outside the Netherlands?

Yes, as long as it happens inside the European Union. The law requires the work to be done in an EU member state. If a Dutch employer's staff do part of the work in another EU country, those hours still count, provided the employer is established in the Netherlands and pays Dutch payroll tax for those staff. Work done in Seoul, Tokyo or Singapore does not count.

Hours worked elsewhere in the EU follow the same record-keeping rules as hours worked in the Netherlands, and the records have to be kept at the Dutch company.

Sources:
WVA, article 1, definition of speur- en ontwikkelingswerk
RVO, Handleiding WBSO 2026, appendix A

What is WBSO worth in 2026?

According to RVO's 2026 rates, WBSO lowers the payroll tax a company pays by 36% of the first EUR 391,020 of its R&D costs, and by 16% of the costs above that. A company that counts as a starter gets 50% on that first part instead of 36%. R&D costs means the R&D hours times an hourly wage, plus other R&D costs and expenses.

A new Dutch subsidiary usually meets the first test for starters. RVO treats a company as a starter when, in the past five calendar years, it was not a Dutch payroll employer for at least one of those years. Two limits apply. A company can be a starter for at most three calendar years. And if the new company continues the activities of a connected company, its WBSO history can count against it. RVO calls companies connected when one holds at least a third of the shares in the other, or when a third party holds that much in both. A foreign parent can only have a WBSO history if it had a Dutch payroll of its own, so this limit mostly matters for groups that already have another Dutch company.

A company that is new to WBSO has no Dutch payroll history for RVO to calculate an hourly wage from. RVO then uses a fixed hourly wage of EUR 29, in the year of the first application and the year after.

Source: RVO, Handleiding WBSO 2026, sections 1.3.1 and 1.3.3, and appendix A

What does a foreign parent need in place before applying?

A Dutch company with a Chamber of Commerce number, registered with the Dutch tax office as an employer, with R&D staff on its own payroll. It also needs eHerkenning at level 3, the Dutch business login, and it has to apply before the work starts. RVO does not accept applications for work that has already been done.

The order matters, because each step waits on the one before it:

1. Set up the Dutch company and register it with the Chamber of Commerce. See how to set up a Dutch BV from abroad.
2. Register the company as an employer and put the R&D staff on its payroll. See how a foreign company runs payroll in the Netherlands.
3. Request eHerkenning level 3. RVO warns that delivery takes a number of weeks, and a company that is still being formed cannot request it without a Chamber of Commerce number. RVO asks those companies to email wbso@rvo.nl when staff will be on the payroll from the start of the next month.
4. Apply. A company can apply until the last day of any month; the period then starts on the first day of the next month and runs to 31 December. An application covers at least 3 months and at most 12, and a company can file at most four applications a year. To use WBSO from 1 January, apply by 20 December.

The full application process is in how to apply for WBSO, and what the credit is worth over a year is in what WBSO is worth in 2026.

Source: RVO, Handleiding WBSO 2026, sections 2.1 and 2.3

Where WBSO fits in a move to Europe

WBSO rewards payroll a company already has, which is why it is usually one of the first sources of money a landing company can use. It also depends on decisions made much earlier: where the engineers are employed, and when the Dutch company starts paying them. Why this kind of money usually comes before a funding round is explained in Equity-free money first.

Sources

1. RVO, Handleiding WBSO 2026 (PDF, in Dutch), checked 11 September 2026
2. Wet vermindering afdracht loonbelasting en premie voor de volksverzekeringen, version of 1 January 2026 (wetten.overheid.nl), checked 11 September 2026
3. Business.gov.nl, Dutch R&D tax credit scheme (WBSO), checked 11 September 2026

Checked on 11 September 2026. This page is general information, not legal, tax or investment advice. Rules change: check the official source, or ask an adviser, before you act on it.