Manual

WBSO 2024
Commissioned by the Ministry of Economic Affairs and Climate Policy
 Reader’s guide
This WBSO Manual includes an appendix giving an alphabetical list of the most important terms and concepts
employed therein and a brief description of their meaning. Not all R&D projects, activities, companies, costs and
expenditures are eligible for the WBSO. This Manual sets out the preconditions and assessment criteria.

This 2024 WBSO Manual contains information on the WBSO (R&D tax credit scheme) as of 1 January 2024.
The information provided is based on the Wage Tax and National Insurance Contributions (Reduced Remittances)
Act (Wet vermindering afdracht loonbelasting en premie voor de volksverzekeringen (WVA)) and the hereupon based R&D
Remittance Reduction Regulations (Regeling S&O-afdrachtsvermindering).

No changes to the WBSO in 2024.

There are no changes to the terms and parameters of the WBSO for 2024.

In 2024, the fixed deduction for self-employed persons (sole traders) is €15,551. The supplementary deduction for a
start-up entrepreneur is €7,781.

Changes relating to CSR and ICSR

Corporate social responsibility (CSR) and international corporate social responsibility (ICSR) (Internationaal
Maatschappelijk Verantwoord Ondernemen (IMVO)) will become less noncommittal, due to expected legislation and
EU directives. This may also bring changes for your business. It is therefore essential that you prepare your
business in advance.

CSR and ICSR centre on considering the effects of your business activities on people, animals and environment.
We ask you, as an entrepreneur to act in accordance with the www.rvo.nl/oeso-richtlijnen As WBSO advisers, we can
help you by offering advice. Would you like to find out more? www.rvo.nl/mvo.

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 Contents
Reader’s guide 2
1. In brief  4
1.1 Lowering the costs of R&D 4
1.2 The WBSO in 8 steps 4
2. Who is eligible? 8
2.1 R&D tax withholding agents 8
2.2 R&D taxpayers 8
3. What kinds of R&D project are eligible  9
3.1 Development project 9
3.2 Technical scientific research 12
4. What activities are ineligible 14
4.1 Ineligible work activities 14
4.2 Preconditions 15
5. Which costs and expenditures come into consideration? 16
5.1 Fixed sum or costs and expenditures 16
5.2 Conditions attached to costs and expenditures 16
5.3 Examples of eligible costs 17
5.4 Examples of eligible expenditures 17
6. More about costs and expenditures 18
6.1 General exclusions  18
6.2 Excluded costs  18
6.3 Excluded expenditures 18
6.4 Examples of WBSO projects with their costs and expenditures  19
6.5 Calculation of costs 20
6.6 Costs versus revenues 21
6.7 Attributing expenditures 21
7. What do you gain from the WBSO? 24
7.1 Tax credits for enterprises acting as tax withholding agents 24
7.2 Tax advantage for R&D taxpayers (self-employed persons) 25
7.3 Extra tax incentives for start-ups 25
8. How and when should you submit a WBSO application? 28
8.1 Preparing and submitting your application  28
8.2 WBSO project questions  31
8.3 How do we assess your application? 31
8.4 When can you expect a decision? 32
9. Administrative records 33
9.1 Why are you required to keep administrative records? 33
9.2 What R&D administrative records should you keep? 33
9.3 What are the consequences of incomplete administrative records? 35
9.4 How long must you retain the R&D administration records? 36
10. Applying your WBSO tax credit 37
10.1 Deduction of the R&D withholding tax credit for R&D tax withholding agents 37
10.2 Deduction of the R&D tax credit for R&D taxpayers (self-employed persons) 39
10.3 Settlement of revised R&D Declarations 39
11. How do you make a statement? 42
11.1 Statement 42
11.2 Actual hours, costs and expenditures 43
12. Inspection 44
12.1 Retrospective inspections by RVO 44
12.2 WBSO corrections and fines 44
12.3 Objections and appeals 44
13. Checklist 45
14. Calendar 47
15. Glossary 48

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 1. In brief
Tekst vervangen door: Are you an entrepreneur and An application can be submitted for either of two types
are you conducting Research and Development (R&D) of project, namely:
activities? Or are you planning to conduct technical- • the development of technically new (components of )
scientific research? The WBSO (R&D tax credit - physical products,
scheme) helps you to lower the costs of research and - physical production processes, or
development. The Ministry of Economic Affairs and - software;
Climate Policy has commissioned the Netherlands • technical scientific research.
Enterprise Agency (RVO) to implement the WBSO.
The WBSO in 8 steps
1.1 Lowering the costs of R&D 1
You intend to carry out research or development
The WBSO (R&D tax credit) is a Dutch Government tax
incentive scheme that offers compensation for part of
your research and development (R&D) wage costs,
other costs, and expenditures. In practice the scheme 2
You submit a WBSO application, together with
reduces your payroll tax burden. Self-employed persons Citizen Service Numbers if required
are granted a fixed tax-deductible item for their R&D.
In addition, start-up entrepreneurs benefit from a
supplementary credit. 3
You organise your administrative records system

1.2 The WBSO in 8 steps

4
Below you will find a brief explanation of 8 steps how
Advisers check your application to verify that it is complete
to apply for the WBSO.
NB: You always have to apply for a WBSO R&D tax credit
in advance. Retrospective applications are not
permitted.
5
Advisers review the contents of your application and
issue a Decision
Step 1: You intend to carry out research or development
You plan to carry out R&D. When deciding whether to
start an R&D project, one of your considerations will be 6
its expected cost. The WBSO exists to help you finance After having received this Decision you deduct the R&D tax credit
from your tax return
your project or projects.

The WBSO lowers the cost of technical scientific 7

research and development, even if the project fails to You submit a statement of your actual R&D hours worked,
yield the desired result. Every entrepreneur in the and of costs and expenditures where this is relevant

Netherlands planning to carry out R&D can apply for

WBSO tax credits, unless the organisation is a public
knowledge institute. The company can be of any size 8
and can be working in any business field. Officials may visit your business to carry out an inspection

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 The parameters for the WBSO in 2024 are: Step 2: You submit an application
• the percentage of the 1st tax bracket is 32%; You can submit your WBSO application using the
• the upper limit of the 1st tax bracket remains online application portal on mijn.rvo.nl/wbso.
€ 350,000; Level 3 of eHerkenning is a requirement for this.
• the percentage of the 2nd tax bracket is set at
16%; If you received an R&D Declaration in 2022 and have
• the percentage of the 1st tax bracket for carried out R&D activities, you must also supply the
start-ups is 40%; citizen service number (burgerservicenummer, bsn)
• The R&D deduction for self-employed of all your 2022 R&D staff, so that we can calculate your
persons is €15,551; average R&D hourly wage in 2024. These R&D
• the supplementary R&D deduction for employees have to be registered in your R&D time
self-employed persons considered start-ups sheet administration for 2022.
becomes € 7,781;
• the WBSO budget is set at 1,446 million. Chapter 8 explains how to complete and submit an
application in more detail.

Fill in the online financial calculation tool so that Step 3: You organise your administrative records system
you can quickly find out whether you can apply Your R&D administrative records for the WBSO must list
for the WBSO and what your a­ dvantage is. the nature and content of, progress in (project
administration), and scope (time sheet administration)
If you would like to quickly find out whether of your R&D work. If your first application is for a tax
you could be eligible for a WBSO tax credit and credit on the basis of actual costs and expenditures, then
also which financial benefits the WBSO could you are under the obligation to keep administrative
offer you, use the online calculation tool records of the costs and expenditures actually incurred for
Regelhulp WBSO on www.regelhulpvoorbedrijven/ each R&D project. If in your first application you choose
wbso. By answering a number of questions, you for costs and expenditures based on a fixed amount,
will find out: then no separate administration of the actual costs and
• whether you can apply for the WBSO and/or; expenditures is required. Make sure that you keep
• which financial benefits the WBSO could administrative records from the very beginning of the
offer you. project(s), even if you have yet to receive your R&D
By answering the questions, you will also gain Declaration.
an insight into a number of conditions that you
will need to meet. This will make it easier for Chapter 8 explains in more detail how to complete and
you to apply for the WBSO. submit an application.

Step 4: Advisers check your application to verify

Application portal eRecognition and supply it is complete
chain authorisation After your application has been received, advisers from
• You should log into the application portal RVO inspect your application to verify that it is complete.
with at least level 3 eRecognition (eH3) and a If this is the case, you will receive confirmation in the
level 3 authorisation for RVO services. application portal and the advisers will then handle the
• If you are an intermediary or an agent, in details of your application. If your application is
addition to eH3, you will also need a supply incomplete, you are offered one opportunity to
chain authorisation for each company to log supplement the application with the additional
into the portal. Please apply for supply chain information that is required. Make sure that RVO receives
authorisation in good time. You can read this information within the specified time, as your
more information about supply chain application will not be processed if you do not submit
authorisation on the www.eherkenning.nl/ this information in time. Once your application is
ketenmachtiging. complete, you are issued a confirmation of receipt in the
application portal
Would you like to know more?
More information on using the application portal
is available on
www.rvo.nl/wbso/aanvraagproces.

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 Step 5: Advisers review the contents of your Tips to speed up the processing of your application:
application • Do not submit at the last minute. RVO processes
Once your application is complete, advisers from RVO will applications in order of receipt.
review its contents: they review the projects listed in the • Submit your application in full. You will be given one
application, and their costs and expenditures, against the opportunity to provide additional information for
relevant laws and regulations. If the specifications incomplete or free-form applications. RVO can only
of your projects or their costs and expenditures process your application once it is complete.
contain insufficient information for the review of your • Describe the projects clearly. This way you can prevent
application, they may ask you questions. This may be RVO having to ask questions. Do not give a general
carried out through the application portal or by description, but describe in concrete detail what you
telephone. RVO may also consult public sources to want to research or develop. Describe primarily the
investigate the level of knowledge and expertise within technical rather than the functional or business-
your company, e.g. LinkedIn profiles, public websites or economic aspects, as the space on the application form
Google search results.1 RVO uses all the information you is limited. Always describe the activities that will be
have submitted to reach a decision on your application. carried out by you yourself, as the applicant,
The decision will be laid down in a decision document particularly in collaborative projects.
and can be viewed on the application portal. You will • In case the project(s) are a joint effort between you and
receive a notification email about this. other legal entities, please name the collaborating
parties and specify their contribution to the project(s).
If your application for WBSO is approved in full or in part, If your projects are not described clearly, RVO will need
this Decision will be issued to you together with an R&D to ask questions. This means that the decision on your
Declaration. The Decision specifies the number of hours application will be delayed.
and, where relevant, the costs and expenditures allocated • It would be preferable not to add any appendices.
to each project. The projects that do not come into Appendices delay the handling process.
consideration for the WBSO are also specified and • Request your eRecognition in good time. You can use
explained in this decision. this identification to submit your application through
https://mijn.rvo.nl/wbso. This will require eHerkenning
The R&D Declaration specifies the maximum amount of (level 3). You will receive the identification from the
the R&D tax credit deduction that you are entitled to apply supplier within two weeks after the order. If you are
to the payroll tax number without sub-number (RSIN) using an intermediary or agent, please arrange the
specified, in the period to which the Declaration applies. supply chain authorisation in good time.

When can you expect a decision? Objections and appeals

In the case of an application for a fixed sum, a technical You may lodge an appeal against the full or partial
consultant will reach a decision on your application for rejection of your application for a WBSO tax credit by
WBSO tax credit within three calendar months of the date submitting a notice of objection, with reasons. If you are
on which the period covered by the application begins. unable to agree with RVO’s decision on your notice of
In the case of an application for the actual costs and objection, then you can lodge an appeal with the Trade
expenditures, this period is eight weeks longer. and Industry Appeals Tribunal. If, after due consideration,
The processing period is suspended if the advisers your objection or appeal is met in full or in part, you will
reviewing your application need to submit a written receive a supplementary R&D Declaration. It is possible
request for supplementary information. that you receive this supplementary Declaration only after
the end of the period to which your application applies.
The sooner you receive your research and development
declaration, the sooner deductions can begin. RVO aims Step 6: You deduct the R&D tax credit from your tax
to process all applications within the statutory period. return
However, you can also ensure that RVO can make a You deduct the R&D tax credit you have been granted
quicker decision about your application yourself. from your payroll tax returns. If you are a self-employed
person and you have spent 500 hours or more on R&D,
you may deduct your R&D tax credit from your income
tax return.

1
From May 24, 2018, the General Data Protection Regulation (GDPR) applies to all the member states of the European Union.
The GDPR (AVG in Dutch) is the successor of the Wet bescherming persoonsgegevens (Wbp) in the Netherlands. The AVG gives people more
control over their personal data. Companies and authorities are required to have a legal basis for the processing of personal data and
are obligated to handle personal data with care. More information about the AVG can be found at https://www.rvo.nl/over-ons/privacy.

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You will find more information on this subject in Declaration. You will also receive a revised R&D
Chapter 10. declaration in case your R&D administrative records
contain hours for activities, costs and expenditures for
Step 7: You submit a statement of your actual R&D which you have not received an R&D-declaration or
hours worked, and the costs and expenditures contain costs and/or expenditures that have not been
You submit a statement of the actual R&D hours worked incurred (solely) for the purpose of, and are directly
and the actual costs and expenditures incurred, where allocable to your R&D activities. RVO may also impose a
relevant, within three months of the end of fine.
the calendar year covered by the R&D Declaration
concerned. If you are a self-employed person, you need Chapter 12 details this retrospective inspection and its
to provide this statement only if you spent less then possible consequences.
500 hours on the approved R&D activities.
On the basis of this mandatory statement, RVO may issue Inspections
a revised R&D Declaration. RVO will withdraw your R&D We ensure that you are in compliance with all
declaration(s) if you are a self-employed person who has WBSO conditions when using the scheme.
carried out less then 500 hours R&D work. Our WBSO officials may carry out desk
inspections or conduct an inspection at your
Information on when and how to make the mandatory company. In order to carry out an inspection,
statement can be found in chapter 11. we may request that you submit part of or all of
your R&D administrative records. In such cases,
Step 8: Officials may carry out an inspection you will receive a binding request regarding the
RVO conducts retrospective inspections. These may be inspection we intend to carry out, the
desk inspections or on-site inspections at your company. information we require and the deadline by
If any errors are identified in your R&D administrative which time you are required to submit the
records, then you will be issued a revised R&D relevant data.

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 2. Who is eligible?
Apart from public knowledge institutes, every be hired in or out for R&D, for example, by an
entrepreneur in the Netherlands planning to carry personnel company or by companies within a tax entity
out R&D can submit an application for a WBSO tax that are carrying out work on a specific project. When
credit. The company can be of any size and can be employees are hired in and out by companies within a
working in any business field. The WBSO tax entity then each company employing those
distinguishes between entrepreneurs who withhold employees will need to submit an application.
payroll taxes (inhoudingsplichtigen) and those In other words, if employees of two companies
subject to income tax (belastingplichtigen). – company A and company B – are working on a
This chapter contains an explanation of these specific R&D project and company A also hires in
regulations and also explains what you need to do employees from company B, then both companies A
when a tax entity or an operating company with a and B will need to submit an application. However,
holding company is involved. supplier company B will then be deemed to be carrying
out the R&D work that takes place at hiring company A.
Both A and B must comply with the administrative
2.1 R&D tax withholding agents obligations as described in chapter 9.
If you elect to apply for an R&D tax credit against actual
Do you conduct a business within the meaning of the costs and expenditures instead of a fixed sum, you may
regulations on corporate tax? Do you employ staff who also cite the costs and expenditures incurred by other
carry out R&D? If so, you are eligible for a deduction in companies within your tax entity to the extent that
the payroll tax you are required to pay, unless you are a these costs and expenditures are incurred exclusively
public knowledge institute (see the list of definitions as a result of the R&D being carried out.
in an appendix to this manual).
Those who conduct a business which is not a public Trainees
knowledge institute, carry out R&D and withhold The R&D hours worked by trainees and students
payroll taxes on behalf of their employees are referred working on their graduation project may be included
to by the WBSO as ‘R&D tax withholding agents’. in the specification of R&D hours worked for the WBSO
A holding company can also be deemed to be an R&D only if they are employed by the company and all the
tax withholding agent if at least one employee carries R&D conditions are met.
out R&D. You are a withholding agent for the purposes
of payroll tax when you employ staff and the Dutch Tax
Authorities has issued you a payroll tax number. 2.2 R&D taxpayers
Note! A change in your company’s legal entity creates
a new withholding agent! Make sure that you always Are you a self-employed person? Do you conduct a
submit your application for the correct withholding business within the meaning of the Income Tax Act
agent. 2001? And do you work on R&D for at least 500 hours in
a calendar year? If so, you are eligible for an R&D tax
Holding company / operating company credit. This category of self-employed persons is
Do employees of your holding company and employees referred to as ‘R&D taxpayers’. Self-employed persons
of your operating company carry out R&D? If so, both who conduct business via two or more companies they
the operating company and the holding company must singly or jointly own that are engaged in R&D may
submit an application. submit more than one application.
As a self-employed person you cannot claim for costs
Tax entity and expenditures, and you cannot choose a fixed sum.
Do you hire out R&D employees to a third party? If so, If you are a self-employed person, but you also have
these employees fall under the WBSO only when they salaried employees who carry out R&D work, you can
organise the R&D work at the third party’s company. also apply for a WBSO tax credit for these employees,
An exception to this is made, however, for hiring in or as a payroll tax withholding agent and claim costs and
hiring out employees within a tax entity for the expenditures or choose a fixed sum. More information
purposes of corporate income tax. Employees may can be found in chapter 5.

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 3. What kinds of R&D project
are eligible
The WBSO extends support to two types of project: Technical innovation
1. Development projects The most important criterion to be met for development
This concerns the development of technically new work is: does the object constitute a technical
(components of ) physical products, physical innovation for you? Development work is not always
production processes or software. R&D work: routine development work, for instance, is
2. Technical scientific research not R&D work. Your technical ability and your technical
This concerns explanatory research that is technical knowledge always serve as the benchmarks. Technical
in nature. innovation requires the presence of a research element
in the project or technical uncertainties or risks relating
These two project types are explained in more detail to the achievement of the required result. Your WBSO
below. Each type of project is governed by specific application will need to contain an explicit specification
assessment criteria. These are always based on the of the technical problem or the bottleneck that you are
principle that the applicant is the party that carries addressing and of the outline solution that you have
out the work. Examples of projects are used to explain adopted or intend to research. This technical innovation
why specific projects are classified as R&D projects criterion is applicable to each individual applicant,
whilst others are not. In your application, you even when the work has been commissioned or will be
describe the R&D activities you intend to carry out. carried out within a collaborative arrangement.

Technical innovation is characterized by the activities

3.1 Development project your company is carrying out. Such activities go beyond
the application of existing knowledge and/or technology.
The WBSO offers support for developments that are R&D activities are typified by identifiable technical risks
technical innovations for you. This can relate to the and/or uncertainties and don’t necessarily lead to
development of products, production processes, or desired results.
software, or their component parts. The work in the
development of products and production processes A project that is eligible for WBSO support is
must relate to tangible, physical objects. characterised by a concrete technical problem that you
are working to solve. Starting with a specific choice of
Development work is always about searching and proving. direction, your company will be working to devise new
You want to develop something yourself and run into a technical principles, methods, or technologies, or
technical problem. You are trying to find a new solution further develop an existing technology.
for which you want to demonstrate the working principle
yourself, for example in a prototype. A development Please note!
process must involve technical risks or uncertainties. There is a difference between the terms ‘new’ and ‘technically new’.
If you are able to achieve the end result based on common techniques
or well-known working principles, then this does not fall within the
definition of development for the purposes of the WBSO. Activities
that involve the copying, imitation or reverse engineering of existing
technology are ineligible.

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 Prototype
A prototype is the actualisation of an operating principle Development example: prototype with
that can demonstrate whether a given choice of solution commercial value
actually works. A prototype has commercial value if it has A breeder develops technically new plants.
commercial significance or can be used as an operating During the development specimens of these
asset. A prototype will have commercial significance if you plants are sold to a customer. These specimens
can sell it or use it to provide services to (potential) clients. are regarded as (early) prototypes because they
It is not relevant whether or not costs are charged or paid. will be checked against the criteria established
The hours devoted to the building of a prototype with in advance (such as specific breeding
commercial value may not be counted as part of R&D objectives). Because the prototypes are sold,
hours. This also means that no WBSO claim may be made they have, however, end-user value. This means
against the costs or expenditures incurred by the building that the ‘development hours’ for these
of such a prototype. prototypes are not regarded as R&D activities.
Development hours include: care, processing,
A number of examples are given below to illustrate the treatment, transport, storage and interbreeding
development of prototypes with and without commercial activities.
value, and the concept of technical innovation.

Development example: prototypes Development example: technical

without and with end-user value innovation of a purification plant
(company equipment) One of the elements of the development of
A pharmaceuticals manufacturer develops a new production process concerns the
a sorting machine for its in-house production development of a purification plant. The design
lines. The operating principle is tested using of a purification plant on the basis of tried and
a prototype made from structural steel. tested technology does not involve the
As there is then a risk of the pharmaceutical development of a technically new product,
products becoming contaminated with rust, process or process step and does not involve
this prototype is clearly not suitable for use in R&D work. This work is often referred to as
production lines and it therefore has no engineering. However, the development of
commercial value. The hours spent on the a purification plant which incorporates a new
construction of this prototype are regarded as operating principle can involve R&D work.
R&D hours. However, the hours the The application will then need to include an
manufacturer spends on the construction of the explicit specification of the technically new
definitive version from high-grade stainless elements of this purification plant as compared
steel are no longer regarded as R&D hours. to the customary design of purification plants.
The reason is that the first prototype only What will it add to the applicant’s existing
demonstrated the operating principle of the technical knowledge? Which technical
sorting machine, while this definitive version bottlenecks could be resolved using existing
has actual commercial value. knowledge and expertise?

If development work is limited to the

Development example: prototype without development of a technically new element in
commercial value the purification plant, R&D work may possibly
A manufacturer of central heating boilers is limited to the development of that component
developing a new type of central heating boiler. part. R&D work ends once the operating
This central heating boiler will ultimately be principle of that element has been
manufactured in mass production. A prototype demonstrated. Consequently, the design and
being constructed by the applicant during the construction of the entire purification plant and
development process will be used to test the the use of the technically new element of the
operating principle. Once the operating plant is not regarded as R&D.
principle has been demonstrated, the prototype
will be scrapped. The hours spent on the
construction of this prototype are regarded as
R&D hours.

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 Technically new software Projects in which software is developed to integrate
For the WBSO, the context of ‘technically new software’ existing components or allow them to work together in
has to be a problem in the field of information a technically new manner are also regarded as R&D
technology. To determine whether software projects. Pursuant to a supplementary condition, you
development can be regarded as R&D, two concepts will need to have developed the existing software
(besides actual development) are of importance: components primarily in-house and to have already
‘software’ and ‘technically new’. Software is defined as implemented them in your company.
the non-physical, logical subsystem of an information The explanation of this definition reveals that not all
system that determines the structure of the data and its the activities involved in the development of software
processing to the extent that this subsystem is fixed in a come into consideration for WBSO support. Activities
formal programming language. The development of focused on the application, collation or implementation
technically new software is iterative in character. of software are deemed to be construction work and
It must pivot on the applicant’s actual resolution of not R&D. Nor are projects focused on the design and
software-technical bottlenecks. The R&D period comes construction of new functionality (building blocks,
to an end when you successfully demonstrate a new modules and packages, etc.) based on existing or
IT-based operating principle. The time spent on available technologies (software and techniques) or the
describing models, formulating algorithms or construction of a new system deemed to constitute
describing the architecture when no technical R&D projects. This is still applicable even if you first
bottlenecks are being resolved is not regarded as work need to become familiar with the technology and train
on the construction of technically new software. staff, perform a study, or make purchases.
The demarcations employed in defining ‘new software
‘Technically new’ has a meaning different from that of development’ are explained in the following examples.
‘new’. Virtually all software written is new, as it did not
exist before it was written, but this does not necessarily Example of non-development of software:
mean that the software is ‘technically new’. new database and network environment
The distinction between ‘new’ and ‘technically new’ is An example of a project that is not an R&D
made clear by the answers to the following questions: project because it involves the use of existing
technology is a project for the construction of
1. Does the software incorporate a new data a new information system in which the new
processing-related technological principle, and aspects are a new database environment and
2. Will you be addressing the technical obstacles in a new network environment. The project is
your programming work yourself? primarily focused on the applicant’s design of
The answer to both questions must be ‘yes’. an application and the achievement of the
The development of a new principle may render necessary functionality. The search for the
software ‘technically new’ for the applicant. optimum design and most suitable components
are not regarded as R&D, as the work is
It is important to make a distinction between projects application-oriented rather than technology-
and problems. A project can, for example, relate to the oriented.
design of a new route-planning system. This could be
confronted by an information technology problem,
namely that the required specifications cannot be Example of non-development of software:
achieved with the existing algorithm. You will then new development platform
need to specify this problem as clearly as possible in The fact that a development environment is
your application. The development of a new and more completely new to a software developer and
efficient algorithm may require the development of that the developer will need to begin by
new methods and techniques, i.e. technically new learning new methods and techniques
software. The simple description or formulation of a (first use) does not make it an R&D project.
new algorithm, without its concrete execution by the This learning phase is regarded as training,
applicant in a formal programming language, is not and not categorised as R&D.
deemed to constitute R&D.

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 Example of development of software Example of non-development of software:
A business is specialised in building apps for coupling of machinery
mobile phones. The applicant intends to construct A company has purchased a number of
an app that can serve as a voice-controlled search machines in order to create a new production
engine. Augmented Reality is involved, in that process. The company creates a dashboard
the user can initiate a search command to search using C# and uses available APIs for the
for text information about the user’s current exchange of data between the machine and the
surroundings. This search for content can range administrative systems.
from information about the history of an area or
building to information about restaurants in the
vicinity. The business develops the software for 3.2 Technical scientific research
both the speech processing on the mobile phone
and for the reduction of the smartphone’s power Research projects that you carry out to generate new
consumption. technological knowledge can, subject to certain
conditions, be deemed to constitute technical scientific
research. The meaning of technical scientific research
Example of non-development of software: is explained further below on the basis of the terms
application of machine learning ‘technical’ and ‘scientific’.
A business develops an application for doctors.
The purpose of the information system is to Technical
make suggestions regarding medication and ‘Technical’ refers to research in fields such as physics,
treatment. The company collects, assesses and chemistry, biotechnology, production technology, or
interprets a range of data through the use of information and communication technology. Research
machine learning and natural language into fields such as economy, sociology or psychology
processing, which is then used as the input for cannot be deemed to constitute technical scientific
the application. A model is created and trained research. The results from the research do not need to
using techniques such as TensorFlow. This be suitable for application in a technically new physical
model is then applied in the field. product or production process.

Scientific
Example of development of software: ‘Scientific’ relates to the objective and results of the
development of bots and AI technology research, as well as to the manner in which the
A business develops bots and AI technologies research is designed and implemented:
for the handling of online customer contacts.
The company also develops technology • Objective and results: the objective of scientific
designed to process the Dutch language, to research is to find an explanation for a phenomenon
manage decision trees and to measure that cannot be derived from generally available
intentions. Backend development takes place in knowledge. Your research generates theoretical or
Python, with the company developing software practical knowledge. Simply collecting data or
in R for statistical processing. information does not constitute scientific research.
Scientific research sets out to be explanatory.
A number of process innovations are accompanied by Research that does not extend beyond noting,
IT solutions. The following two examples clearly show describing, observing, surveying, coding, classifying
when companies fall within the definition of software or interpreting is not scientific research. Scientific
development (R&D) and when they do not. research is accompanied by the risk of failing to find
the explanation for a phenomenon. The results from
Example of software development: the research are determined on the basis of facts.
synchronisation of machinery • Design and implementation: the design of the
A company has purchased two machines for a research must be known at the time of the
particular production process. The challenge application. Scientific research must be designed
lies in synchronising, monitoring and calibrating and carried out in a structural and planned manner.
both machines in real time to a large extent. The research is not of a routine nature. Clear records
The machine manufacturer is unable to provide of the research programme and the results are
any relevant solutions. The company develops required. The results from the research do not need
software in C to allow for real-time communication. to be reproducible and the determination of the

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 statistical confidence is not required. Nor is it Example of non-TSR: tomato sauce
necessary to develop new concepts, laws or theories, manufacturer
or to explain unknown operating principles. An entrepreneur wishes to prolong the shelf life
of his company’s tomato sauce by combining
The following examples illustrate the meaning of alternative preservatives with heat treatment.
technical scientific research (TSR) in more detail. The flavour of the product, however, should
not be affected. The entrepreneur carries out
Example of TSR: chemical plants a series of tests with various alternative
An entrepreneur is looking for an explanation preservatives and heating times. The study
to account for unexpectedly rapid corrosion at identifies the impact of the various alternative
chemical plants. The company suspects that the preservatives and heating times. The
corrosion is caused by microbially induced entrepreneur determines the treatment for the
corrosion, but is unable to find any publicly best product based on these results.
available information on the subject. The Establishing links, relationships or correlations
entrepreneur carries out chemical, metallurgical is not regarded as technical scientific research.
and microbiological measurements to test this The entrepreneur has not carried out research
hypothesis. The company examines what types into the underlying mechanisms of action in the
of corrosion processes are taking place at the tomato sauce in order to account for the
plants and how these processes can be differences in shelf life.
impacted. The hypotheses are validated
following analysis of the measurements.
Example of TSR: pasta sauce manufacturer
A pasta sauce manufacturer is unfamiliar with
Example of non-TSR: injection moulding the way in which microorganisms are affected
company by heat treatment and alternative
An injection moulding company observes preservatives. The company carries out a
abnormalities in its products when using microbiological study into the cellular
regenerate instead of new plastic granulate. mechanisms that come into effect when
The entrepreneur has a general idea of what the microorganisms are exposed to heat and
problem may be. In order to get a better alternative preservatives. The study seeks to
understanding of the conditions in which the explain the difference in levels of heat tolerance
problems arise, the company carries out a and tolerances to alternative preservatives of
Design of Experiments (DOE). This allows the the various types of microorganisms in the
company to identify and situate the problem pasta sauce.
in broader terms, however, no attempt is made
to find an explanation for the product
abnormalities observed when using regenerate. Example of TSR using deep learning

A company is conducting research on the

Example of non-TSR in relation to data operating mechanism of a protein as the catalyst
science model for a specific chemical conversion because this
A food manufacturer plans to conduct research can sometimes be a slow process. In order to
on the quality of the cleaning method for the determine the 3D structure of the protein and
production installation based on measurement the catalytic effect, the company uses both
and historical data. The manufacturer wants to traditional applications and a deep learning
be able to determine when cleaning is the most approach The company compares the results of
efficient in order to make chemical, energy and both procedures and on that basis wants to find
time savings. Data scientists will process the an answer for the slow catalytic effect.
data in a model. The model will be used to
make predictions on the quality of cleaning and
the optimal use of cleaning agents.

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 4. What activities are ineligible
Not all the work carried out within the context of
R&D projects can be deemed to be R&D work. • the construction of a pilot plant on production scale
The text of the WBSO regulations, now incorporated or a prototype having evident production or
into the Wage Tax and National Insurance commercial significance;
Contributions (Reduced Remittances) Act (WVA) and • work carried out by the R&D tax withholding agent
the R&D Remittance Reduction Regulations or R&D taxpayer in connection with the R&D carried
(Regeling S&O-afdrachtsvermindering) define what out by a third party that cannot as such be deemed to
is and is not understood as R&D work. The Act lays constitute R&D;
down a specification of work that constitutes R&D • work on modifications of or changes to existing
work, while the R&D Remittance Reduction products or processes that are not of technological
Regulations list a number of explicit exclusions. significance;
This chapter reviews these exclusions, concluding • work on the formulation and modification of recipes
with a list of preconditions that your work will need and the composition of a product that does not
to meet if you are to be eligible for WBSO support. result in a technically new operating principle of the
relevant product;
• the formulation and testing on non-technical
4.1 Ineligible work activities specifications;
• the formulation or determination of functional
The following work activities do not constitute R&D requirements and preconditions;
and are not covered by the WBSO. • the formulation and implementation of tests that
• market research; are not directly and exclusively directed towards
• organisational and administrative work; demonstrating an operating principle by the R&D tax
• work carried out outside the European Union. withholding agent or taxpayer;
(The United Kingdom is not part of the European • any of the following software-related activities:
Union); 1. software maintenance
• the construction or installation of equipment 2. the description of a software architecture
intended for use in practice; 3. designing or building a new system
• work relating to the implementation and adjustment 4. adapting software for use on another hardware or
of technology, products, processes or software, or software platform. By ‘platform’ is meant the
parts thereof that have been or are to be purchased, overall hardware and operating system
without prejudice to the provisions of ... [point 5 of environment on which information systems are
this page]; developed (the development platform) or taken
• research into the presence of minerals; into production (target platform).
• the performance of policy studies and strategic studies; 5. The development of software that enables the R&D
• the organisation and attendance of courses, training tax withholding agent or R&D taxpayer to integrate
programmes and symposia; existing software components or allow them to
• the analysis and assessment of existing production work together in a technically new manner, unless
processes when there is no direct link to the the existing software was developed and is
company’s own R&D; employed principally within the R&D tax
• research that compares products when there is no withholding agent’s company, within the tax entity
direct link to the company’s own R&D; of which the R&D tax withholding agent is a part, or
• work solely on changes to the design or dimensions within the enterprise of the R&D taxpayer.
of products and software;
• quality control other than the control of the R&D
that is carried out, and quality assurance;
• work on structural and installation designs based on
existing techniques;
• preparations for and the performance of production
work;

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 The following are not considered R&D 4.2 Preconditions
hours:
• attendance at fairs and conferences The following preconditions are attached to granting a
• attendance at training programmes, courses WBSO tax credit:
and symposia • A project-based approach must be adopted for the
• the administration of R&D or other adminis- R&D (or a programme-based approach when this is
trative and organisational activities more compatible with the specific situation).
• the supervision of trainees and graduation- • The R&D project must be planned.
project students • You must organise and carry out the R&D work
• building and technical installation designs yourself. Consequently, when you carry out the work
• making a product production-ready pursuant to a commission or in a collaborative
• projects not applied for and/or not approved arrangement you will need to be able to demonstrate
• activities not directly and exclusively linked to that you carry out the R&D work yourself and that
the R&D project you determine the management of the project.
• activities performed outside the European • When employees are hired in and out by companies
Union within a tax entity, each company (employing those
employees) will need to submit an application.
Regardless of where the employees carry out their
The following staff members are not held R&D activities, the company formally employing
to perform R&D hours: these employees is considered carrying out the R&D
• non-salaried staff members (e.g. trainees or work and therefore responsible for the WBSO
graduation-project students) application.
• staff members not involved in a project in a • The R&D work must be carried out within the
technical capacity (e.g. secretaries, designers jurisdiction of the European Union (EU). You may
or marketing managers) include the R&D hours worked by your employees in
other Member States of the EU in your statement of
the actual R&D hours worked if you, as the employer,
Applying for the WBSO for a project that is have your registered office in the Netherlands and
already at an advanced stage the R&D work is carried out by your employees for
In 2023, you developed a new machine, but you whom you withhold payroll tax in the Netherlands.
did not apply for the WBSO. In 2024, you will Self-employed persons who carry out R&D in the EU
carry out tests and apply for the WBSO for the for their own company with its registered office in
project for the first time. However, the the Netherlands may also include the necessary
performance of test activities alone does not hours worked in their statement of the actual R&D
constitute R&D. As such, the project is not hours worked. The administrative requirements
eligible for WBSO support. governing R&D hours worked in another EU Member
State are identical to those governing R&D hours
worked in the Netherlands. The R&D administrative
records must be available at the Dutch branch of the
company.
• If you are applying for the WBSO for a project for the
first time, our assessment of your application will
not include the consideration of activities you have
already carried out and for which no application has
been submitted. However, an exception will be
applied in situations in which another company in
the tax entity was granted the WBSO for earlier
phases of the project.

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 5. Which costs and expenditures
come into consideration?
If you, as a withholding agent, apply for WBSO If you elect the ‘fixed sum’ approach, this choice applies
support, then in your first application of a given to all subsequent applications made in that calendar
calendar year you can choose one of two types of year. In other words, you will no longer be able to
claim: either the actual costs and expenditures of submit a claim against the actual costs and
your own R&D, or a fixed sum which approximates expenditures.
to these costs and expenditures. In both cases, these
costs are in addition to your R&D wage costs. Your Actual costs and expenditures
WBSO tax credit (the amount you deduct from your The additional amount will be calculated on the basis
payroll tax bill) is then calculated on the basis of this of the estimated costs and expenditures in relation to
total amount and specified in your R&D Declaration. the research and development work. If you choose
actual costs and expenditures in your first application
of the calendar year, you can no longer use the fixed
5.1 Fixed sum or costs and costs regime that calendar year. This means that if the
expenditures actual costs and expenditures are less than expected,
you cannot choose the fixed amount at a later date.
Whether you opt to apply for a fixed sum or by declaring
your actual costs and expenditures, an amount is added
to your R&D wage costs. Your WBSO tax credit (the 5.2 Conditions attached to costs and
amount you deduct from your payroll tax bill) is then expenditures
calculated on the basis of this total amount and
specified in your R&D Declaration. The following Costs and expenditures will only be eligible for an R&D
section explains these two options. declaration if they (exclusively) serve the performance of
and are directly attributable to your own R&D activities.
Fixed sum
In this simple arrangement, the supplementary amount Not all the work involved in R&D projects can be
is calculated by reference to the number of allocated deemed to be R&D work. Administrative and
R&D hours. The fixed sum is a rough estimate of the organisational work, for example, is not deemed to be
costs and expenditures that the average entrepreneur R&D work. Costs attributable to these activities are not,
(irrespective of the specific business sector) will incur therefore, taken into consideration by the WBSO.
in carrying out R&D. You can choose the fixed sum
option even if your actual costs and expenditures differ This is shown in the following diagram:
considerably from the fixed sum estimate.
Limits involved in R&D work and the WBSO
WBSO: costs and expenditures
The fixed sum amount per calendar year is:
• € 10 per R&D hour for the first 1800 R&D hours;
• € 4 per R&D hour for all R&D hours above the Start of project End of project
R&D work
first 1800.

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Only those costs or expenditures that are directly 5.3 Examples of eligible costs
attributable to the R&D work carried out by the
withholding agent come into consideration for the Depending on the R&D being carried out, the following
WBSO. This means that these costs and expenditures two cost types will be taken into consideration:
must have a directly demonstrable causal link to the 1. the purchase of non-durables, materials and parts
R&D being carried out. with which to carry out experiments or make trial
batches;
The costs relate to costs paid in connection with the 2. the purchase of materials and parts needed for the
performance of in-house R&D to the extent that these in-house construction of a prototype having no
payments: potential production or commercial value, within
• serve solely for the performance of your own R&D; the framework of an in-house development project;
• are borne by the R&D tax withholding agent, or by a • the costs incurred in arranging for the
company within the tax entity of the R&D tax construction of prototypes that will not ultimately
withholding agent; serve a potential production or commercial
• not qualify as expenditures. purpose;
• the purchase of licences for specific software tools
The term ‘serve solely’ means that 100% of the costs or ICT tools required for the in-house
must serve the performance of your own R&D rather development of technically new software;
than other purposes. In other words, costs must be • the costs incurred in renting equipment or leasing
fully (100%) attributable to in-house R&D. (parts of ) buildings used solely for R&D work.

‘Expenditure’ relates to payments in connection with

the purchase of new operating assets to the extent that: 5.4 Examples of eligible
• these operating assets have not been used before; expenditures
• these operating assets serve for the purpose of the
in-house R&D; Depending on the R&D being carried out, the following
• the payments are made at the R&D tax withholding expenditures may come into consideration:
agent’s expense or that of a company within the tax • buildings or sections of buildings to the extent that
entity of the R&D tax withholding agent. these are directly used for in-house R&D work;
• the purchase of new equipment or instruments
Note! specifically intended for the construction of models,
• An expenditure comes into consideration for the WBSO in the year preparation of trial batches or manufacture of
that the operating asset is put into use. prototypes that will not ultimately serve a potential
• A given expenditure can be included in only one R&D Declaration production or commercial purpose;
per calendar year. • the purchase of ICT tools specifically intended for
• When the expenditure on an individual item of operating asset in-house R&D.
amounts to € 1,000,000 or more in a calendar year, then a
maximum of 20% of the purchase price comes into consideration Please note the FAQs about costs and expenditures at
for the WBSO. You may then claim a maximum of 20% of this www.rvo.nl/wbso.
purchase price in the WBSO application for a total of 5 calendar
years, provided that the operating asset is used for the purposes of
R&D in those years.
• You may only enter costs and expenditures in the statement that
you have included in the application and that RVO has allocated.
This applies to each project rather than to each application.

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 6. More about costs and
expenditures
Not all costs and expenditures incurred by an R&D Indirect costs and expenditures
project come into consideration for WBSO support. Only those costs and expenditures that are directly
Costs and expenditures must have a demonstrable attributable to R&D come into consideration for the
direct causal link to the R&D being carried out. WBSO. Examples of indirect costs and expenditures that
The details are laid down in the applicable Act and are excluded from the WBSO include:
Regulation R&D withholding tax credit. • subscriptions to newspapers and magazines/journals;
• training programmes and courses;
• visits to trade fairs and conferences;
6.1 General exclusions • the R&D director’s lease car;
• licences for software and computers for general
Costs and expenditures incurred by activities that do company use.
not constitute R&D
Costs and expenditures are taken into consideration for
WBSO support only if these are directly ascribable to 6.2 Excluded costs
and, in the case of costs, exclusively devoted to the
applicant’s in-house R&D activities. If the activities in The following costs are not taken into consideration
question do not fall within the remit of the WBSO, then for WBSO support:
neither do any associated costs and expenditures. • wage costs
• the cost of outsourced R&D, for example a payment to a
Examples of activities and the associated costs/ university for a public private partnership;
expenditures that do not come into consideration for • costs of hiring in labour;
the WBSO include: • depreciation costs;
• building a prototype that is likely to have a • financing costs;
production or commercial significance. This means • costs incurred by the purchase or improvement of land;
that the prototype can be used as an operating asset • costs forming a remuneration for the disposition of
for production or used to provide services to capital equipment for which the applicant (or another
(potential) customers. If it is likely that the prototype entity) was already awarded an R&D Declaration.
can be sold, it has commercial significance. Costs for
e.g. materials that are used to build the prototype
will not be eligible for the WBSO. 6.3 Excluded expenditures
• market research: activities related to market research
are excluded from the WBSO. Consequently, any The following expenditures do not come into
associated costs are excluded from the WBSO. consideration for the WBSO:
• applications for and the maintenance of patents: • ICT tools for general use;
applications for and the maintenance of patents • second-hand operating assets. Solely new company
are not deemed to constitute R&D. Consequently, equipment (or parts of company equipment) that
the costs incurred in applying for and maintaining has not been used previously comes into
patents do not come into consideration for the consideration for the WBSO. Nor do machines that
WBSO. have been used previously and are assigned a new
• preparations for production: all costs incurred in use come into consideration for the WBSO;
starting up and preparing for production are not • investments that are eligible for an Energy
covered by the WBSO. Costs incurred in production Investment Allowance (EIA) or Environmental
losses do not come into consideration for the WBSO. Investment Allowance (MIA);
• equipment, instruments or facilities for R&D to be
carried out by third parties.

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6.4 Examples of WBSO projects with WBSO technical scientific research
their costs and expenditures An entrepreneur wishes to increase his
knowledge of catalysts in order to prolong their
service life. His research is focused on reaction
WBSO development project kinetics. The entrepreneur seeks explanations
A manufacturer of central heating boilers is for both the fouling and degeneration of the
developing a new type of central heating boiler. catalyst. Laboratory experiments are carried out
This central heating boiler will ultimately be to test the theoretical backgrounds.
manufactured in mass production. A prototype
being constructed during the development Examples of costs that qualify for WBSO support:
process will be used to test the operating • expenditures incurred in the purchase of
principle. Once the operating principle has been laboratory equipment used for the research;
demonstrated, the prototype will be scrapped. • costs incurred in the purchase of the raw
The hours spent on the construction of this materials used in the laboratory experiments;
prototype are regarded as R&D hours. • costs incurred in arranging for third parties to
carry out the laboratory tests;
Examples of costs and expenditures that qualify • costs incurred in the purchase of software
for WBSO support: specifically required for simulations and/or
• costs incurred in the purchase of parts for the analyses.
construction of the prototype;
• costs incurred in the purchase of new Examples of costs and expenditures that do not
measuring instruments required to carry out qualify for WBSO support:
the tests. • visits to trade fairs (not directly attributable
to R&D);
Examples of costs and expenditures that do not • use of a company laboratory (this does not
qualify for WBSO support: involve paid costs);
• costs incurred in hiring employment agency • the costs incurred in hiring in employment
staff for the performance of the tests (this agency staff to perform tests in the company
involves hiring in labour); laboratory (this involves hiring in labour).
• depreciation on existing test equipment
(depreciation is not a paid cost);
• costs incurred in acquiring a patent (not R&D). WBSO development project
Agreement: development hours and related
costs/expenses
Development project A breeder uses the latest techniques to develop
Not Agreed: development hours and new edible plants and donates some of these
related costs/expenses plants to charity. Charity then gives away the
A breeder develops technically new plants. edible plants to people who are temporarily
During the development specimens of these unable to manage themselves financially.
plants are sold to a customer. These specimens These donated plants are not seen as
are regarded as prototypes with end-user value prototypes with end-user value (see 3.1). As a
(see 3.1). As a result, also the costs and result, costs/expenses related to the
expenditures related to the development hours, ‘development hours’ for the donated plants,
e.g. costs for nutrition, storage, analyses, e.g. costs for nutrition, storage, analyses,
laboratory equipment, breed- and reproduction laboratory equipment, breed- and reproduction
facilities, fertilization and energy, do not qualify facilities, fertilization and energy can also be
for WBSO support because these costs and claimed.
expenditures are not related to R&D activities.

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 6.5 Calculation of costs from the company’s general warehouse. The
use of the materials for R&D is calculated based
Costs must be directly attributable to and exclusively on the number of R&D hours relative to the
serve the performance of R&D and must therefore have a total number of hours worked in the laboratory.
clear and demonstrable causal link with R&D. In your This cannot be considered an objective
application, you must describe which costs you believe you calculation. The costs for the materials used
will incur as part of the project as well as the associated may not be determined in this manner and are
amounts. In your statement, you must report the actual therefore not eligible.
costs incurred and paid for the performance of your R&D
activities. These costs will have been recorded in your
R&D records in the execution of your WBSO projects. General costs, such as rental costs or expenses for gas,
The costs are incurred the moment they are incurred water and electricity, are generally not directly
for your R&D work. attributable to R&D and are not exclusively serviceable
to that purpose. Expenses for gas, water and electricity
It is not always simple, however, to determine at first are only eligible if you are able to objectively determine
glance how much of these costs have been incurred for their actual use in relation to your R&D activities.
R&D purposes. This can be the case with, for example, Regarding the calculation of the rental costs of parts of
raw materials or floor stock that are purchased in bulk, buildings, only specific areas that are delineated,
partly for R&D purposes and partly for other business objectively ascertainable and used exclusively for R&D
activities. After all, any related invoices will refer to all will be deemed eligible.
purchased raw materials and not specifically to the
portion used for your R&D purposes. Example: market gardener’s gas,
water and electricity consumption –
In a number of cases, it is possible to determine the calculation approved
portion of the total of such costs that is exclusively A market gardener owns multiple greenhouses.
of service to R&D. Any such determination must be a One greenhouse is used exclusively for R&D
clear and realistic calculation based on objective data, purposes. The greenhouse in question is
i.e. based on facts and findings, measurements or metered and the consumption of gas, water
pure consumption registration data. Estimates or and electricity in this specific greenhouse is
assumptions based on historical data may not be used in measured and registered separately. The eligible
the calculation of costs. Below follow several examples costs can be objectively determined using the
of cost items determined using cost calculations based actual consumption in this greenhouse and the
on objective and verifiable data, as well as cost items unit price of gas (€/m³), water (€/m³) and
determined otherwise. These costs do not exclusively electricity (€/kWh).
serve the performance of your R&D activities.

Example: steel usage in prototype – Example: office building lease costs –

calculation approved calculation not approved
A machine manufacturer purchases steel and The R&D employees of a company conduct
uses a portion of it in its R&D work on a development activities in a leased office
prototype without user value. The fixed unit building. Non-R&D employees also work in
price per kilo of steel can be determined from this building. Approximately half of the total
an invoice. By measuring the weight, the number of hours worked by all employees is
machine manufacturer can ascertain how many spent on R&D. In this case, applying 50% of the
kilos of steel were used in the prototype. lease costs of the entire office building would
The eligible costs can be determined by not be allowed, since the office building does
multiplying the fixed unit price of the steel (€/kg) not exclusively serve the purpose of R&D.
by the weight of steel used in the prototype.

Please note!
Example: floor stock for laboratory – If you include costs under the WBSO, your R&D records must
calculation not approved demonstrate how you arrived at your calculations.
A chemical company has a laboratory whose
activities include R&D. Materials needed by the
lab, such as pipettes and test tubes, are taken

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Please note! Example: raw material costs for trial products
You may only state costs that you have included in the application A manufacturer of packaging develops new
and that RVO has allocated. This applies per project, not per packaging material (a new product).
application. These costs must solely serve and must be directly To demonstrate the operating principle of the
attributable to the R&D activities. In addition, the costs you specify in product, trial products are manufactured on the
the statement must be paid no later than three months after the end production line. The applicant views the output
of the calendar year. of the trial products as waste, which is sold on
for a modest amount to a recycling company.
The trial products are necessary to demonstrate
6.6 Costs versus revenues the operating principle of the product in
development and are not prototypes with user
Costs incurred in your R&D activities may also be value. The costs of the raw materials used in
associated with revenues. In some cases, you will need manufacturing the trial products qualify for
to deduct the revenues from the costs. The eligibility of WBSO support. The revenues do not need to be
the costs and any requirement to deduct revenues will deducted from the costs that qualify for WBSO
depend on the answers to the following questions: support.

1. Are the costs related to the production of

a prototype? If the costs of your R&D activities are not directly
2. Does the prototype in question have user value? related to the manufacture of a prototype, but have
contributed to the generation of revenues, these
If a prototype that is manufactured has user value, revenues must be deducted from the costs.
i.e. a potential commercial or productive meaning,
the hours spent manufacturing the prototype will by Example: animal feed developer
definition not qualify for WBSO support. In that case, An animal feed developer purchases pigs to test
the costs of purchasing materials and components to a new animal feed in development. Following
construct the prototype will also not be eligible. the project, the pigs represent a significant
potential revenue and are sold. The pigs are not
Example: raw material costs for trial products part of the prototype manufactured as part of
A manufacturer of packaging develops new the project, since the R&D is focused on the
packaging material (a new product). development of the animal feed. The pigs were
To demonstrate the operating principle of the necessary for the testing procedures, the aim of
product, trial products are manufactured on the which was to demonstrate the working
production line. The trial products are always principle of the animal feed. The costs of
customer orders that will be subject to reduced purchasing the pigs are therefore directly
prices should the quality of material fall short of attributable to the R&D. However, because the
expectations. While the trial products are applicant also generates revenues by selling the
necessary to demonstrate the operating principle pigs, the pigs do not exclusively serve the
of the product in development, they do have purposes of the R&D. By setting off the
user value, as they are sold to customers. The revenues against the costs, it is possible to
packaging material is allocated a designated determine the portion of the costs that did
use for which the product was also intended. exclusively serve the purposes of the R&D.
The costs of the raw materials for these trial The costs that qualify for WBSO support are the
products are not eligible, since the raw materials acquisition value of the pigs minus the revenues
are used to construct prototypes with user value. generated by the eventual sale of these pigs
following the animal feed tests.

In certain situations, prototypes are considered to have

no user value, even though they generate modest
revenues. In such cases, you must deduct the revenues. 6.7 Attributing expenditures
However, you must be able to demonstrate that the
prototype has neither a productive nor a commercial Expenditures that are directly attributable to and serve
significance. the purpose of the R&D are deemed eligible.
The purchase of the newly manufactured operating
asset must therefore have a clear and demonstrable

21 I 2024 WBSO Manual

causal link with your R&D activities. In your Example: mixer for yoghurt production
application, you must describe which expenditures you A dairy develops a new yoghurt for which it
believe you will incur for the project as well as the purchases a special mixer. This special mixer is
associated amounts. You must take into account the necessary due to specific mixing techniques
expected application of the operating asset for your required to produce the yoghurt. This mixer is
R&D. You must specify the actual expenditure incurred also deployed for regular production. A part of
and paid in the statement, taking into account the part this mixer can now be eligible, because the
of the operating asset that served your R&D. You must operating asset partly serves the purpose of
account for this expenditure and the percentage that R&D. This can be determined using the number
served your R&D in your R&D administration. of hours the mixture is used for R&D purposes
compared to the number of hours the mixture
The portion of the eligible expenditure is determined is deployed for regular production, measured
from the date on which the operating asset has been from the date of commission of the mixer
commissioned until the end of the calendar year. through to the end of the year. Such a
The attributable portion of the expenditure must be calculation must be substantiated by means of
objectively ascertainable and serve the purposes of the actual registrations in the R&D records.
R&D. You will need to substantiate this calculation in
your R&D records. In the case of expenditures of
€ 1,000,000 or more, you must annually determine Example: R&D building
the purchase value of the operating assets that is The company has a new R&D building erected that
attributable to and used for R&D, for a maximum of cost a total of €800,000 (after deduction of
five calendar years. A maximum of 20% of the purchase non-eligible components). The building is not
amount qualifies for the WBSO per year. used exclusively for R&D. The degree of service to
Example: you spend € 3,000,000 on purchasing a new R&D can be determined by multiplying the portion
machine, which is used in equal measure for R&D of the building with an R&D function (m2) by the
(50%) and regular production (50%) in the year of degree of use of these spaces for R&D in the
commission. The portion that is attributable to and period from the occupation of the building through
used for R&D is 50% of € 3,000,000 = € 1,500,000. to the end of the year. In this case, 63% of the
This expenditure must be spread over a maximum building’s surface area consists of spaces where
of five calendar years. It follows that in the first year, R&D is carried out. The other spaces are general
50% of 20% of € 3,000,000 = € 300,000 is eligible. spaces, such as toilet facilities, reception, hall and
office space. Imagine that the building is occupied
If the portion of the expenditure that is attributable to as of 1 March and that, from that date through to
and used for your R&D is less than € 1,000,000, you the end of the year, 58% of all activities conducted
may include this amount only once in your WBSO in the spaces with an R&D function are indeed
application. Example: you spend € 1,200,000 on R&D-related activities. The eligible expenditure is
purchasing a new machine, which is used for 60% for therefore: 0.63 * 0.58 * € 800,000 = € 292,320.
R&D activities and for 40% for production in the year of
commission. The portion that is attributable to and
used for R&D is 60% of € 1,200,000 = € 720,000. As this
portion of the expenditure is less than € 1,000,000, it
may be included only once in your WBSO application.

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 Example: new production process Please note!
A company develops a technically new If you partially include expenditures under the WBSO, your R&D
production process and purchases operating records must demonstrate how you arrived at your calculations.
assets in order to create this process on a 1:1 This calculation must be substantiated based on actual registrations.
scale and demonstrate the operating principle. An estimate will not be approved.
Following completion of the R&D project, the
process is deployed for production. The Please note!
expenditures related to the creation of the You may only state expenditures that you have included in the
production process do not qualify for WBSO application and that RVO has allocated. This applies per project, not
support, as it involved the construction of a per application. Expenditure specified in the statement must also be
production-scale pilot plant or building a paid no later than three months after the end of the calendar year.
prototype with a productive significance.
A alculation based on the use for R&D purposes Please note!
versus deployment for production does not An item of expenditure can only be included in one R&D declaration.
apply here because the operating asset is not If an operating asset has been granted through a previous application,
directly attributable to and does not serve the but you also wish to use it in a new project for which you will be
performance of R&D activities. submitting a follow-up application, then you must highlight your
intention to use the previously granted expenditure for this project on
the application form for the new project. You may not apply for that
amount again.

23 I 2024 WBSO Manual

 7. What do you gain from
the WBSO?
The financial advantages offered by the WBSO differ basis of the data in your payroll tax returns for 2022.
for companies acting as withholding agents and RVO needs the citizen service numbers (bsn’s) of your
self-employed persons. Start-up enterprises or employees who carried out R&D work in 2022 to make
entrepreneurs are entitled to additional financial these calculations. These R&D employees have to be
advantages, referred to as the ‘start-up facility’. registered in your R&D time sheet administration for
This chapter explains how your financial advantage 2022. You can submit these citizen service numbers
is determined. simply via the internet. If you were issued an R&D
Declaration for 2022, RVO will issue the necessary
information.
7.1 Tax credits for enterprises acting
as tax withholding agents Note!
Submit your bsn’s of 2022 in time! Only then your application will be
The WBSO offers companies acting as withholding processed. Do this before or along with your application. Bsn’s of
agents a deduction from the total payroll tax they are 2022 are necessary to calculate your R&D hourly wage for 2024.
required to pay. This deduction from the payroll tax to If we do not receive any bsn’s, we will not process your application.
be paid is referred to as the ‘R&D withholding tax
credit’. In 2024 this deduction amounts to 32% of the RVO requests information about the taxable wage and
first € 350,000 of the total underlying R&D cost and the hours paid for the R&D employees that you
16% of the remaining costs. The ‘total underlying R&D specified from the Employee Insurance Agency (UWV).
cost’ is made up of the total R&D wages on the one The UWV receives these data from the Dutch Tax
hand, and the costs and expenditures (or a fixed sum Authorities. The information issued by the UWV is
based on the number of allocated R&D hours) on the based on the data in the UWV’s policy records on the
other. There is no upper limit to the total R&D cost reference date. The reference date for the wage data for
against which the R&D deductions are calculated. 2022 is set at 1 April 2023.
These percentages may be adjusted once each year, but
this has no effect on any R&D Declarations issued
before the adjustment. The R&D hourly rate is set as follows:

Determination of R&D wages in 2024 Total wages paid to all R&D employees
RVO calculates the R&D wages by multiplying the R&D R&D hourly
hourly wage by the number of allocated R&D hours. 0.85 x total hours paid for all R&D employees
The R&D hourly wage is a fixed average hourly rate
applicable to all your R&D employees. This R&D hourly The factor 0.85 serves as compensation for
wage is used for the further processing of your leave. The result is rounded up to the nearest € 1.
application or applications and is applicable to the The calculated hourly wage applies to the
entire 2024 calendar year. The R&D hourly wage is whole of the 2024 calendar year, so you need to
determined as follows. provide bsn’s.

If you did not carry out any R&D work in 2022, then
your hourly wage will be set at an average of € 29
(fixed amount).

If you did carry out R&D work in 2022 and were issued
an R&D Declaration for that work then RVO will
calculate the average R&D hourly wage for 2024 on the

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A change in your company’s legal entity creates a new (see chapter 8); the R&D hours corresponding to more
withholding agent! Your company is then governed by than one R&D Declaration are added together. So the
the standard hourly wage of € 29 in the year in which minimum number of hours that have to be spent on
the first application is submitted and the next calendar R&D is not reduced accordingly if an application is
year. This is also applicable when you, as a new submitted which only applies to part of that calendar
withholding agent, have taken over R&D personnel year. If your first application is in May, you still need to
from a predecessor or from another company. perform at least 500 R&D hours during the rest of the
year to qualify for R&D tax deduction. Self-employed
Determination of the total underlying R&D cost persons can claim no costs or expenditures for
The total underlying R&D cost is the sum of the R&D themselves, nor can they elect the fixed sum approach.
wages (number of R&D hours x R&D hourly wage) and If you are self-employed and your enterprise employs
the costs and expenditures (or a fixed amount based on salaried staff, then the regulations for R&D tax
the number of allocated R&D hours). withholding agents apply to those employees. In your
WBSO application, you can apply for your own R&D
Examples of the determination of total work and the R&D work of your employees. As for your
underlying R&D cost employees, you can choose a fixed amount or actual
You submit an application for 2024, comprising R&D costs and expenditures. When you comply with all
4,000 R&D hours. The hourly wage is € 25. You the WBSO conditions, you will receive an R&D
have elected the ‘fixed sum’ approach. You declaration for you and your employees.
receive your R&D Declaration.

The total R&D wage is € 100,000 (4,000 hrs x 7.3 Extra tax incentives for start-ups
€ 25/hr). The costs-related fixed sum awarded
is: (1,800 x € 10) + ((4,000 – 1,800) x € 4) = The WBSO offers extra support to start-ups. Here, too,
18,000 + 8,800 = € 26,800. a distinction is drawn between tax withholding agents
(employers) and tax-paying persons (the self-employed).
The total underlying cost on which the R&D tax You can be deemed to be a start-up company for a
withholding deduction is calculated is then maximum of three years.
€ 100,000 + € 26,800 = € 126,800. The R&D tax
withholding deduction awarded is 32% of R&D tax withholding agents
€ 126,800 = € 40,576. An R&D tax withholding agent deemed to be a start-up
company is eligible for an R&D tax credit of 40% on the
In the event that you do not elect the fixed sum first € 350,000 of the total underlying R&D cost (see 7.1)
approach, and declare (for instance) costs of in 2024.
€ 20,000 and expenditures of € 325,000, then
the total underlying costs on which the R&D tax R&D taxpayers (self-employed persons)
withholding deduction is calculated are A self-employed person deemed to be a start-up
€ 100,000 + € 345,000 = € 445,000. In that case, entrepreneur is eligible for a supplementary R&D tax
the R&D tax withholding deduction awarded is credit of € 7,781 in 2024.
32% of € 350,000 and 16% of the remaining
€ 95,000 = € 112,000 + € 15,200 = € 127,200. When is a company deemed to be a start-up?
To determine whether an enterprise should be
designated as a start-up, the following criteria are
considered:
7.2 Tax advantage for R&D • Your enterprise has had salaried employees for less
taxpayers (self-employed than five years, or you have been an entrepreneur
persons) for less than five years.
• Your enterprise has been issued R&D Declarations
The WBSO offers the R&D tax deduction to self- for less than three calendar years. Whether your
employed persons if they carry out at least 500 hours company continues the activities of another
of R&D in a calendar year. The amount of the deduction company may play a role in this regard.
is set once a year and is € 15,551 in 2024. The 500-hour
threshold applies irrespective of the number of These criteria are explained in more detail below.
applications you submit in a given calendar year. You
don’t need to apply for 500 hours in your first application

25 I 2024 WBSO Manual

 The number of years you have employed staff or are Continuation of activities
an entrepeneur Has your company taken over activities from another
Your company may qualify as a start-up if you were not company, or did your company take over activities from
liable to withhold tax for at least one year in the last another company in the past? If so, this is deemed to
five calendar years. This means that you had employed constitute the continuation of (part of ) a company.
staff in a maximum of four calendar years. As a self- The company from which you took over the activities
employed person, you must have been an entrepreneur does not necessarily need to have been discontinued.
for a maximum of four calendar years in the previous
five calendar years. In both cases, this does not have to If your company continues the activities of another
be a continuous period. company, the R&D Declarations issued to that other
company may in some instances be taken into account
The number of years in which you have been issued when determining the start-up status of your company.
an R&D Declaration This is determined by the ownership structure of your
You can be deemed to be a start-up company for a company.
maximum of three years. If you have been issued R&D
Declarations in three or more of the past five years then The examples in the next text boxes explain the
you no longer come into consideration for start-up meaning of ‘continuation’ in more detail.
status. This does not need to be a consecutive period;
each calendar year in which you were issued one or The ownership structure: ‘affiliation’ and
more R&D Declarations then counts as one year. If ‘substantial interest’
specific conditions are met, the R&D Declarations If your company A continues the activities of company B
issued to a company of which your company is a and company B holds at least 1/3 of the shares in
continuation are also taken into account. This is company A then the companies are held to be ‘affiliated’.
determined by the continuation and ownership This is also the case if company A holds at least 1/3
structure criteria that are explained below. of the shares in company B or if a third party holds at
least 1/3 of the shares (directly or indirectly) in both
Examples of continuation company A and company B.
• A one-man business or a share in a general
partnership is converted into a private If your company A continues the activities of a
limited company. The activities of the self-employed person B and this self-employed
one-man business or general partnership are person B holds more than 5% of the shares in
continued by the private limited company. company A, then self-employed person B is said to
• A private limited company is split into a hold a ‘substantial interest’.
holding company and an operating company.
The activities of the former private limited If activities are continued and either affiliation or a
company are continued by the holding substantial interest are an issue, then the R&D
company and/or the operating company. Declarations issued to the continued company /
• Two or more companies merge to form a self-employed person B in the previous five calendar
new company that continues the activities of years are taken into account in the determination of
the former private limited companies. the start-up status of company A.
• The activities of a private limited company
are split and transferred to two new private The examples explain the meaning of ‘affiliation’ and
limited companies that each continue part of ‘substantial interest’ in more detail.
the activities of the former private limited RVO determines whether you are to be assigned
company. start-up status. This assessment is carried out on the
• The activities of a bankrupt private limited basis of the information you are required to enter in
company are restarted by another private the application software. If you have any doubts about
limited company. the applicability of start-up status to your company you
• A director and major shareholder transfers can contact the help desk. Were you assigned start-up
his activities from an operating company to status and it subsequently transpires that the
his personal holding company. information you submitted to RVO was incorrect?
Then your start-up allowance will be revised.

26 I 2024 WBSO Manual

 Example of affiliation (indirect): continuing Example of affiliation (direct):
the activities of another private limited continuing the activities of another private
company limited company
Private limited company B was issued R&D Private limited company B was issued R&D
Declarations in 2022 and 2023. The activities of Declarations in 2022 and 2023. The activities of
private limited company B are continued by private limited company B are continued by
private limited company A. Private limited private limited company A. Private limited
company A has never been issued an R&D company A has never been issued an R&D
Declaration and employed its first personnel in Declaration and employed its first personnel in
2024. In 2024 , private limited company A 2024. In 2024, private limited company A
submits its first application for WBSO support. submits its first application for WBSO support.
Private limited company A and private limited Private limited companies A and B are affiliated.
company B are both affiliated with private The two R&D Declarations issued to private
limited company C. Private limited company C limited company B are taken into account when
may have a direct interest in both private determining the start-up status of private
limited company A and private limited company limited company A. In this instance, private
B, but this interest may also be indirect and be limited company A is a start-up company solely
held by intermediate private limited companies. in 2024 as a new company can be a start-up
In this instance, private limited company A and company for a maximum of three years. Private
private limited company B are indirectly limited company A will no longer be a start-up
affiliated. The two R&D Declarations issued to company in 2025.
private limited company B are taken into
account when determining the start-up status
of private limited company A. Private limited Example of substantial interest (direct):
company A therefore still qualifies as a start-up conversion of a one-man business into a
company in 2024. Private limited company A private limited company
will no longer be a start-up company in 2025. A one-man business was issued R&D
Declarations in the period from 2019 to 2023
inclusive. As from 2024, the one-man business
is converted into a new private limited
company. The owner of the discontinued
one-man business holds a substantial interest
in the new private limited company. The private
limited company is not a start-up company in
2024, as the one-man business had already
been issued three R&D Declarations.

27 I 2024 WBSO Manual

 8. How and when should you
submit a WBSO application?
In this chapter, you will read how you can best prepare 4. Company details
an application, when you can submit an application, After you have logged into the application portal
what project questions you can expect in the with eH3 and selected ‘Nieuwe aanvraag’ and
application programme, how we will assess your ‘WBSO’, the details of your company (name under
application and when you can expect a decision. the Articles of Association, payroll tax number
(RSIN) and address) will be retrieved from the
Dutch Commercial Register (NHR).
8.1 Preparing and submitting your
application 5. Copy former projects
Did you apply for the WBSO before? Approved
Would you like to submit a WBSO application? Prepare projects from previously submitted applications
your application using the focus points below. (also through eLoket) will be available for you and
you can simply select and copy them to your new
1. Request eHerkenning/supply chain authorisation application under the ‘Projects’ step on the form.
If you wish to submit a WBSO application for 2024,
you must be able to identify yourself online using an 6. Do you have an intermediary?
eHerkenning tool that is at least Level EH3. Please You can easily submit your own WBSO application.
take into account that it may take several weeks for If you have any questions, please do not hesitate to
your credentials to be issued. If you are an contact one of our advisers. This is free of charge. If
intermediary or an agent then, in addition to EH3, you will be using an intermediary to submit your
you will also need supply chain authorisation to log application, make careful arrangements and
in. Please request supply chain authorisation in request supply chain authorisation in good time.
good time. Please find more information on supply You can find further information about the use of
chain authorisation on www.eherkenning.nl/ an intermediary on the website https://www.rvo.nl/
ketenmachtiging. For more information, please visit subsidies-financiering/wbso/aanvraagproces/wel-geen-
www.rvo.nl/wbso. intermediair (in Dutch).

2. Determine the application period 7. Prepare your project questions offline

Determine the period for which you want to apply Do you prefer to prepare your application offline?
for the WBSO. Each application you submit Please answer the project questions on the project
automatically runs up to and including 31 forms (pdf ). Please answer the other questions
December. You should therefore include the online. You can simply import the answers into the
proposed R&D hours (and any costs and PDF under the ‘Projects’ step in the application
expenditures) up to and including 31 December in programme. Submitting the application online
your application. For more information, please see will therefore be much quicker. The project forms
the text box in this chapter. (pdf ) are available on www.rvo.nl/wbso/
aanvraagproces.
3. Use the online application programme
You will find the application form on mijn.rvo.nl/ 8. Make a realistic estimate of hours spent
wbso. Log in with eH3, select ‘Nieuwe aanvraag’ and You should provide a realistic estimate of the time
then ‘WBSO’. needed for each project (and any costs and
expenditures) up to and including 31 December in
your first application for the calendar year. View
Tips in the green block on page 30 when
submitting a new application. Projects for which

28 I 2024 WBSO Manual

 you only predict a small number of R&D hours 14. No bsn’s, no decision
spent on research and development do not, in If you are a company (R&D withholding agent)
principle, qualify as R&D. Self-employed applying for WBSO for 2024 and you used the
individuals must spend at least 500 hours on R&D WBSO in 2022, you must submit the citizen service
per year to be able to make use of the WBSO. numbers (bsn’s) of the employees who carried out
the R&D activities in 2022 in order to calculate the
9. Choose fixed amount or actual R&D costs and expenditures hourly R&D wage for 2024. Do this before or along
Are you applying for the WBSO as a company with your application. If we do not receive any
(R&D withholding agent)? In this case, you need to bsn’s, we will not process your application. For
choose between the fixed amount (fixed sum for more information and a step-by-step plan, please
R&D costs andexpendituresbased on the number of see the text box in this chapter.
approved R&D hours) and actual R&D costs/
expenditures. The choice you make in your first 15. Running out of time?
WBSO application for 2024 applies for the whole If you need to submit a WBSO application but are
calendar year. If you choose actual R&D costs/ running out of time, you may request a deferral by
expenditures in your application, describe the costs submitting a free-form application. You need
and expenditures at this stage and make a realistic eRecognition 3 (eH3) for this purpose. If you do not
estimate of the amounts per project up to and complete a free-form application, you should
including December. You can find more withdraw it yourself through the application
information about costs and expenditures in portal. Otherwise the free-form application will
Chapter 5 and 6. count towards the maximum of four applications.
If you are an intermediary or an agent, you should
10. Change of legal status? submit a free-form application using your own
Is there a chance that the legal status of your eRecognition tool (eH3). Do not use supply chain
business will change during the application authorisation. While you are logged in, you can
period? In this case, submit an application for submit free-form applications for multiple clients.
the old and the new legal status. However, you must use the supply chain
authorisation from your client to supplement a
11. Is there an operating company or holding company? free-form application. Open the free-form
If both one or more employees from an operating application and select the ‘Aanvullen’ button. If
company and one or more employees from a you log in with your own eH3, you can only
holding company carry out R&D, both the withdraw (but not supplement) a free-form
operating company and the holding company application.
must submit an application. This applies to every
form of cooperation between multiple companies. 16. Digital communication
Make sure you describe your own R&D activities in All communications about your application will be
the application. conducted digitally upon submission.

12. Do not wait until the last day We will send you an email notification if a message
If you would like to use the WBSO from 1 January, is available for you in the portal. The address we
you have until 20 December (in the previous will use for this purpose is [email protected]. Please
calendar year) to submit an application. It is best make sure that the noreply emails from RVO do not
not to wait until the last day, when it is very busy. end up in your spam folder. Answer questions as
Self-employed individuals who would like to use quickly as possible in line with the step-by-step
the WBSO from 1 January can still submit an plan in the notification email.
application up to 1 January.
Keep a check on your email inbox. We would advise
13. Submit your application in full and in good time you to provide several employees access to the
You can speed up the processing of your application email correspondence address that you have stated
if you answer the questions in full and avoid referring in the application.
to previous applications. If you submit an incomplete
application, this will delay the processing of your
application and could lead to questions, your
application not being processed or a rejection.

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WBSO applications For self-employed individuals with no staff
For companies with staff (R&D withholding (R&D withholding agents) the following
agents) the following applies: applies:
• The application period begins on the first day • The application period starts from the date
of the month following the month in which that you submit the application to the end of
you submit the application. One exception the calendar year;
applies. If your application period starts on • Your application can cover multiple projects;
1 January, you should submit your application • You can submit an unlimited number of
by 20 December at the latest. applications per year, there is no maximum;
• Each application you submit automatically • You can submit applications for the current
runs up to and including 31 December. You calendar year up to 30 September;
should therefore include the proposed R&D • If projects run across more than one calendar
hours (and any costs and expenditures) up to year, submit an application for the new
and including 31 December in your calendar year.
application.
• Your application may contain an unlimited Tips
number of projects. • If you would also like to apply for the WBSO
• You can submit applications for the current for your employees’ R&D activities, the
calendar year up to and including 30 regulations for companies with staff (R&D
September. withholding agents) will apply.
• You may submit a maximum of four
applications per year.
• Do the projects continue after the end of the eHerkenning/supply chain authorisation
calendar year? Then you need to submit the If you wish to submit a WBSO application, you
project again in your WBSO application for must be able to identify yourself online using
the following calendar year. Keep in mind an eHerkenning tool that is at least Level EH3.
that you can submit your application for Please take into account that it may take
January by 20 December at the latest. several weeks for your credentials to be issued.
If you are an intermediary or an agent and are
Tips applying for the WBSO then, in addition to EH3,
• Include all R&D projects with R&D hours (and you will also need supply chain authorisation
any costs and expenditures) you have for each company to log in. Please request
budgeted up to and including 31 December in supply chain authorisation in good time. Only
your first application for the calendar year. use your own eH3 for the submission of a
• Only submit a new application: free-form application for a client. Use eH3 and a
- for new R&D projects; supply chain authorisation for the submission
- if there is a change in the content of an R&D of a complete application and for
project, state the changes under ‘Project supplementing a free-form application for a
Update’ on the application form; client. Please find more information on supply
- if you will incur costs and/or expenditures chain authorisation on the www.eherkenning.nl/
other than those you have applied for. This ketenmachtiging.
applies per project, not per application.
- if you will incur more hours, costs and/or
expenditures than you have applied for in Providing citizen service numbers (bsn’s)
total. Not everyone has to provide bsn’s for calculation
of the hourly wage. If you are applying for the
The following applies: the minimum number of WBSO for the first time or did not use the WBSO
hours for a project that you want to replete in 2022, a fixed hourly wage of € 29 will apply.
with a follow-up application is 1 hour. Mention In this case you do not need to provide bsn’s.
the changes in the application form under Self-employed entrepreneurs also do not need to
‘Update project’. provide bsn’s. For them, a fixed deduction applies.

30 I 2024 WBSO Manual

 If you did use the WBSO in 2022, you will need 8.3 How do we assess your
to provide the bsn’s of the employees who application?
carried out R&D activities in 2022. These R&D
employees have to be registered in your R&D First of all, we assess whether the activities you will be
time sheet administration for 2022. We will use carrying out are considered research and development
this to calculate the hourly R&D wage. You can (R&D). To be eligible for the WBSO, you must show
significantly speed up the processing of your convincingly that you will be carrying out research and
request if you provide the bsn’s before or along development yourself. This can also include employees
with your application. You can do this via the who are on your payroll. For R&D activities that are
application portal that is available at https://mijn. carried out by third parties or hired employees, you
rvo.nl/wbso. cannot apply for the WBSO.

If you do not provide any bsn’s, we will not An RVO adviser has knowledge of your field and the
process your application. technology that is central to your project. In order to
assess whether your project(s) involve any type of R&D,
he or she will test your project(s) against the
8.2 WBSO project questions requirements. The questions in the application
program are focused on guiding you to enter the
Please describe which R&D activities you will be relevant information. You should therefore complete
carrying out up to and including December. your application as clearly and completely as possible.
If you opt for the actual costs and expenditures regime, This way we do not need to ask additional questions
you should also state the costs and expenditures you and you will receive a decision on your application
intend to incur. Based on the information provided in sooner
your application, an RVO adviser will assess if you are
eligable and if so, what the amount of the R&D This section gives the most important assessment
(witholding) tax credit is. criteria for WBSO projects. These projects are
You describe your planned R&D activities in one or subdivided into:
more projects. The application form has specific • development project (product or production
questions per project. These questions are focused on process)
guiding you to enter the relevant information. The • development project (software)
more concrete and specific you describe your R&D • technical scientific research
activities, the sooner we can decide on your
application. You will find the questions in the project Your application must also meet specific legal
forms (pdf ) on www.rvo.nl/wbso. requirements, and use of the WBSO also brings a
For each question in the application form an number of administrative requirements with it.
explanation is provided. There is a limit in characters
for answering each question, so please be as concise 8.3.1 Development projects (product or
and specific as possible. We advise you to answer the production process)
questions with the help of the technical employee or
developer who will be (involved in) carrying out the • Are you developing physical, i.e. tangible, products,
project. production processes or parts of these?
• Is there technical innovation?
Only indicate your own R&D activities when answering • Can you state the technical obstacles to the
the project questions (the R&D activities of the development and indicate what the possible
company for which you are submitting the WBSO solutions are? Are there sufficient technical risks?
application). If another entity within your group or Will you be resolving the technical obstacles in your
another company will also be carrying out R&D development work yourself? How will you show the
activities within this project, a separate WBSO intended technical operating principle?
application will have to be submitted for this, stating • Couldn’t the intended solution be easily to achieved
the specific R&D activities and any costs and with existing knowledge and known techniques?
expenditure incurred by this company. Is there no routine development or regular
engineering involved?

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8.3.2 Development projects (software) 8.4 When can you expect a decision?
• Will you be developing technologically new software Approximately 20,000 companies and independent
in a formal programming language yourself? entrepreneurs make use of the WBSO every year.
• Have you described programming-related problems Most applications are received during the month of
in the development of the software? November, with a start date of 1 January.
• Will you be resolving the program technical Applications often cover more than one R&D project.
obstacles in your development work yourself? WBSO advisers assess around 150,000 projects a year. We
• If you will be integrating or working with existing aim to inform you of our decision as quickly as possible,
software in your R&D activities, did you primarily and within the indicated processing period at the latest.
develop and apply the existing software yourself?
• Is there no routine development or building of Submit the application in full to receive a quicker
systems (complete applications) involved? response. Last year, almost 90% of the applications
submitted in full were processed within three months
8.3.3 Technical scientific research from the start of the application period.You can speed
up the processing of your application by:
• Is your research of a technical nature? Does it relate • submitting a complete application straight away;
to fields such as physics, chemistry biotechnology, • completing the application clearly and in full.
production technology or information and The adviser can then assess your application without
communication technology? asking extra questions;
• Are you looking for an explanation for a phenomenon • completing the fields in the application portal and
and is the explanation impossible to find via generally not adding any attachments with text;
accessible knowledge? • providing citizen service numbers (bsn’s) before or
• Does your research go further than stating, describing, along with your application if you also used the WBSO
observing, inventorying, coding, classification or in 2022. These R&D employees have to be registered in
translation? your R&D time sheet administration for 2022.
• Is there a scientific research structure within the This is necessary to calculate the hourly wage in 2024.
project? Self-employed persons does not have to resubmit
bsn-numbers when the tax benefit is a fixed R&D
deduction.

The table below gives an overview of the processing periods.

Completeness of the application Processing period

Start-up *

Complete first WBSO application from a start-up < 1 month after the start of the application period

Subsequent applications from start-ups See the processing periods below

Self-employed individuals (taxpayers)

Application submitted in full < 3 months after submission of your application

Application submitted in free form and incomplete < 3 months after submission of your application + waiting time for your
additional information

Companies (withholding agents)

Application submitted in full + choice for fixed amount 3 months after the start of the application period

Application submitted in full + choice for actual costs and expenditures 3 months + 8 weeks from the start of your application period

Application submitted in free form and incomplete the waiting time for your additional information is added to
the processing period

Questions in writing

the waiting time for your answer is added to the processing period

* start-up: see list of terms at the back of the handbook. The statutory processing periods also apply to start-ups. We aim to process the
complete first WBSO application from start-ups within 1 month.

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 9. Administrative records
The WBSO requires that you keep administrative organisation retains the knowledge acquired during a
records of all the R&D projects for which you have research or development project on the departure of an
received an R&D Declaration. These records must R&D employee. All too often RVO comes into contact
provide clear evidence of the R&D activities carried with companies that have lost all their knowledge
out and the time devoted to them. about an R&D project upon the departure of a specific
If you receive WBSO support on the basis of the fixed employee – and all because no written or digital
sum approach, RVO does not require you to keep a records had been kept during the project.
record of your actual costs and expenditures. If you
were granted WBSO support on the basis of actual In addition to the specified information about the
costs and expenditures, however, you are under the project, you will also need to include the following data
obligation to keep administrative records which and documents in your R&D administrative records:
provide clear and concise insight into the costs and • copies of the application(s) and R&D Declaration(s);
expenditures incurred, and paid, for each R&D • the correspondence with RVO about your
project covered by the R&D Declaration you were application(s);
issued. This chapter contains an explanation of the • any revised R&D Declaration(s) (see also chapters
requirements governing the administrative records by 10 and 11).
reference to a number of questions and answers.

9.2 What R&D administrative

9.1 Why are you required to keep records should you keep?
administrative records?
Appropriate R&D administrative records provide a clear
Once you have been issued an R&D Declaration, and concise insight into the nature and content of the
RVO will carry out an inspection to verify that the project, the progress in and the scope of the R&D work
information submitted in your application is in that has been carried out. Within this context, ‘scope’
agreement with the actual situation. RVO carries out refers to the number of R&D hours (per R&D worker,
these retrospective inspections by visiting companies per day) devoted to the project. It will also, if you have
that have been issued an R&D Declaration. elected for WBSO support on the basis of actual costs
and expenditures, provide details of the actual costs
During these visits RVO inspects the administrative and expenditures.
records to verify that the R&D work specified in the
application was actually carried out. RVO also wishes Project administration
to gain insight into the progress being made on the ‘Project administration’ gives insight into the nature,
R&D projects. content, and progress of your R&D. You are at liberty to
select a project administration methodology that is as
If you have been issued with an R&D Declaration on compatible as possible with your company’s usual
the basis of actual costs and expenditures, then during methods. R&D administrative records can be comprised
a visit RVO will also examine which costs and of a variety of digital and other documents drawn up
expenditures have been incurred and paid for the during the R&D project, such as documents from
R&D work for which the Declaration was issued. meetings, reports, drawings, correspondence, photos
See sections 9.2, 9.3 and 9.4 for more information of prototypes, test results, measurement reports and
on maintaining an R&D administration. calculations, etc. Make sure that these documents state
the date and the name of the author. Collect the
Keeping precise administrative records of your research documents for each project in a separate file and
and/or development results is also in your own interest. supplement them with clear and concise summary reports.
In addition to complying with the statutory You need to file the documentation for each project in
requirements, appropriate administrative records chronological order. You also need to make sure that
provide insight into the results achieved by your R&D. the documents clearly show your technical input in
Keeping administrative records also ensures that your each project. When applying for a software project,

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version control or version management systems on a given day, including non-R&D hours
(e.g. SVN or Github) and issue tracking systems such as (see the example) – is not officially required by the WBSO.
Jira can provide valuable information.
Administration of costs and expenditures
If you have been issued with an R&D Declaration on the
Your R&D administrative records for development basis of costs and expenditures, then for each project
projects also state the technical problems/ you are carrying out you must also keep administrative
bottlenecks you encountered and the outline records that detail its actual costs and expenditures
solutions you have selected to resolve them. and the associated payments, as well as making it clear
Your R&D administrative records for technical how these costs and expenditures you have applied for,
feasibility analyses and technical (or technical are directly (and exclusively) attributable to the
scientific) research also provide insight into the approved and carried out R&D-work. You may only state
design of and the results from the analyses or the costs and expenditures that you have included in
the research analyses or the research. the application and that RVO has allocated. This applies
per project, not per application. The actual method you
use to keep the administrative records for each project
Date documents and name the drafter. Combine these may be as compatible as possible with your company’s
per project in a (digital) folder, with short, clear and customary method.
summary reports. It is important that you archive the
documentation chronologically for each project and Your administrative records can comprise a variety of
that the documents clearly show your technical input documents, including quotations, order confirmations,
in each project. The documents should also correspond invoices and proofs of payment.
with the timesheets and the nature of your technical
input in each project. Do not dispose of documents too If you are also declaring the costs and expenditures
hastily: documents that you will no longer use in a later incurred by another company from within the tax entity
phase may be of importance in an inspection because it to which your enterprise belongs, then these costs and
provides insight into the work for which R&D hours expenditures must also be documented in your R&D
have been written. The R&D administrative records administrative records in a timely way.
must be updated by no later than two months after the
end of each quarter. The administration of costs and expenditures should be
up to date at the time you make your mandatory
You may only state the costs and expenditures that you statement (see chapter 11).
have included in the application and that RVO has
allocated. This applies per project, not per application. When a holding company and an operating
company work on joint projects the R&D
Time sheet administration administrative records must make the role and
The R&D administrative records also specify the days input of both companies clear.
on which an employee carries out R&D work, the
number of R&D hours worked each day, and the
projects the employee has worked on. Make sure that The R&D hours worked must be entered in your
your R&D administrative records are in agreement with R&D administrative records within ten working
the employees’ leave and sick leave records and that days. Your entire R&D administrative records
you have updated the time section of the R&D must be complete within two months of the
administrative records within ten working days. There end of each quarter. The administration of costs
should also be a clear relationship with the project and expenditures must be complete at the
administration. This ten-day period is long enough to moment you make your mandatory statement.
take account of any practical problems that may arise
in maintaining a time sheet on a day-to-day basis, but
short enough to ensure that the time sheet is regularly Not all the work carried out on an R&D project
kept up to date and therefore gives an adequate is deemed to constitute R&D work, for example
overview of the actual R&D hours being made. administrative or organisational work is not
regarded as R&D work. Chapter 4 contains a
A time sheet can be maintained either on paper or complete list of work that is not deemed to
in digital form. To maintain a complete time sheet constitute R&D work.
administration – that is, one that details all hours worked

34 I 2024 WBSO Manual

 Example of a time sheet In Chapter 13 you will find a checklist.
This time sheet can also be downloaded from
www.rvo.nl/wbso > Na uw WBSO-aanvraag >
S&O-administratie bijhouden. 9.3 What are the consequences of
incomplete administrative
In summary, you must remember the following for your records?
WBSO projects:
• check that the personnel working on a project are RVO can inspect your R&D time sheet administration
employees of the company that submitted the records to see how many hours per day given
application; employees devoted to R&D work on a given R&D
• have each employee keep a daily time sheet for each project. These time sheet records must be no more
project and make sure that the time section of the than ten days out of date, and the total number of
R&D administrative records is updated within ten invested hours must agree with the number of hours
working days; specified in the R&D Declaration. If this administration
• do not book hours spent on activities that are not is absent or incomplete, or if it fails to meet the
deemed to constitute R&D work as R&D hours. stipulated requirements, then RVO may issue a revised
Activities that are not deemed to constitute R&D work R&D Declaration or impose a fine.
(see chapter 4) include training programmes, courses
and symposia, administrative or organisational work RVO can inspect your R&D project administration
and hours worked outside the EU; records to determine whether – and, if so, to what
• keep documents such as minutes, reports, sketches, extent – you have carried out R&D work covered by the
drawings, photos of prototypes, measurement reports R&D Declaration that was issued to you. If you do not
and calculations, and file them in your R&D have the R&D administrative records required by law
administrative records; available two months after the end of the calendar
• keep documents such as quotations, order quarter in which the R&D work was carried out, then
confirmations, invoices and receipts of the costs and RVO may withdraw the R&D withholding tax credit
expenditure incurred for your R&D activities and any granted to you earlier in its entirety. It will then be
documents that demonstrate costs and expenditure assumed that no R&D work was carried out. Likewise, if
(solely) serving your R&D activities (please see 6.5 and you have kept administrative records of your projects
6.7). This does not apply if you have elected the fixed but the records do not comply with the stipulated
sum; requirements, for example, because they are missing,
• devote attention to the above points even when the incomplete or inaccurate, the RVO may issue a
project is not a success. corrected R&D Declaration and may even impose a fine.

Example of a timesheet
The timesheet must be updated within 10 working days when R&D Work is carried out at any time throughout the entire project.
Employee
Name:
Position:
Month:
Year:
Activities/time matrix
Number of hours
Project number 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 Totals per month
0,00
0,00
0,00
0,00
0,00
0,00
0,00
0,00
0,00
0,00
0,00
0,00
0,00
0,00
0,00
0,00
0,00

Total

Notes
1) Timesheets do not need to be submitted to RVO. However, the timesheets must be available for an inspection by RVO.
2) Bear in mind that the R&D administrative records must be available within two months of the end of each calendar quarter. Appropriate
R&D administrative records provide a simple and clear insight into the nature and content of the project, as well as the progress in and the scope of
the work being carried out on the project.
3) Copy the internal project numbers from the list of projects enclosed in your WBSO application.
4) Please note that you are obligated to record the time spent on R&D activities within 10 working days of carrying out those R&D activities;
this applies to all R&D work performed throughout the entire project.

35 I 2024 WBSO Manual

RVO can inspect your costs and expenditures application, or if the costs and expenditures actually
administration to check whether you have actually incurred are not the costs and expenditures detailed
incurred the costs and expenditures allocated, and in the application, RVO will issue a revised R&D
whether the requirements of direct accountability and Declaration. This applies per project, not per
exclusivity have been met. This administration has to application. If you have stated costs that not exclusively
be complete at the moment you make the mandatory serve the execution of the R&D project or if you have
statement. The absence or incompleteness of this stated expenditures that not serve the execution of the
administration may incur a revised Declaration or a R&D project, RVO will also correct these. In all cases,
fine. If you have maintained an administration of costs RVO will issue a revised R&D Declaration and possibly
and expenditures, but your time sheet and / or project impose a fine.
administration records do not fulfil the requirements,
a correction in the support given towards costs and
expenditures, to the extent that the work activities 9.4 How long must you retain the
underlying these costs and expenditures are not R&D administration records?
adequately documented in your time sheet and / or
project administration records, can be the result. You are under the obligation to retain the WBSO
administrative records for seven years after the end of
If it transpires that the work activities actually carried the period covered by the Declaration.
out do not conform to the proposed activities in the

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 10. Applying your WBSO
tax credit
Once you have received your R&D Declaration you Deduction within the tax periods
can deduct your tax credit. One of two alternative The date on which your R&D Declaration was issued is of
situations will apply: importance to the deduction of your R&D withholding
• you are an R&D tax withholding agent, and you tax credit. Once you have received your R&D Declaration,
have been granted an R&D withholding tax credit; you may deduct the withholding tax credit from the then
• you are an R&D taxpayer and you have been remaining tax periods. Settlement has been simplified
granted an R&D tax credit. with effect from 2022. You can now personally determine
how much of the allocated WBSO tax credit you wish to
This chapter explains how to deduct your R&D deduct in which tax period. If you have received several
withholding tax credit or tax credit. R&D Declarations, you can add up the amounts
allocated. The deduction of the R&D withholding tax
credit may not result in the reduction of the payroll tax
10.1 Deduction of the R&D to be paid in a tax period to less than zero.
withholding tax credit for R&D
tax withholding agents
You may not deduct the R&D withholding tax
You deduct the R&D withholding tax credit you have credit until RVO issues your R&D Declaration!
been granted from your payroll tax return. The amount
of your R&D withholding tax credit is specified in your
R&D Declaration. The R&D Declaration is issued in the
name of the R&D tax withholding agent. The R&D You may personally determine how much of the
Declaration also specifies the payroll tax number allocated amount of an R&D Declaration you
(RSIN) from which you may deduct the R&D wish to deduct for each tax period. You may
withholding tax credit when you file your payroll tax therefore deduct the total amount in a certain
return. If you have a payroll tax number with various tax period or based on an allocation you have
sub-numbers, such as L01 and L02, then you may divide chosen across the tax periods.
the tax credit between these sub-numbers as you wish.
The credit may be deducted solely from the payroll
tax (wage tax and national insurance contributions). You may deduct the credit granted in the R&D
The credit may not be deducted from the employee Declaration irrespective of the months covered by the
insurance or healthcare insurance contributions. application period in which the R&D hours are actually
You may deduct the R&D withholding tax credit solely worked and the costs and expenditures incurred. If the
in tax periods that end during the calendar year to actual R&D hours worked are at variance with the
which the R&D Declaration relates. Your tax period number of hours granted in your R&D Declaration you
may be of a duration of one month or of four weeks. will need to take action only after the end of the
calendar year (see chapter 11).

The total R&D withholding tax credit you

deduct from your payroll tax may not exceed
the amount specified in your R&D
Declaration(s)!

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 Settlement outside the tax return periods Using an example, the settlement of your R&D tax
If part of the R&D tax rebate has not been settled at the rebate is explained in more detail with correction
end of the calendar year, you may set off the remainder messages outside the tax return periods.
against all periods in the calendar year to which the
R&D statement relates, if there is still room for this.
In that case, you can submit a correction statement for
tax periods that have already expired. Correction
messages are part of the payroll tax system.

Example of the deduction of the R&D withholding tax credit: correction messages
You file a monthly tax return. In January you were issued an R&D Declaration. You have been granted an
R&D withholding tax credit of €10,350. You intend to deduct the maximum R&D withholding tax credit,
with the exception of the second tax period. The payroll tax you are required to pay amounts to € 900 per
tax period.
1. In the first tax period, you deduct the remittance by the maximum amount of payroll tax amounting to
€ 900.
2. In the second tax period, you do not deduct any of the R&D withholding tax credit.
3. In the third and the following tax period you should deduct € 900 on a monthly basis. However, in view
of your gross payroll tax due, you can deduct no more than € 900 of your R&D withholding tax credit
per month.
4. However, as you are unable to deduct more than € 900 of your R&D withholding tax credit, per month,
you have an unused R&D withholding tax credit of € 450 at the end of calendar year covered by the
R&D Declaration. The second tax period still offers scope of € 900 for the deduction of the unused
R&D withholding tax credit. You therefore file a correction message for the second tax period.

R&D Declaration (€ 10,350)

€ 900 € 900 € 900/month
€ 450

Jan Feb Mar Apr - Dec

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Calculation example of a fixed amount of costs and expenditures

Hourly wage = Allocated Allocated Allocated R&D Allocated R&D

€ 20 R&D hours R&D wages (€) fixed sum (€) underlying sum withholding
(€) tax credit (32%)
(€)
R&D Declaration 1 1.000 20.000 10.000 30.000 9.600
R&D Declaration 2 1.000 20.000 8.800 28.800 9.216
R&D Declaration 3 1.000 20.000 4.000 24.000 7.680
Total allocated R&D withholding tax credit € 26.496

Hourly wage = Actual Allocated R&D Allocated fixed R&D underlying Allocated R&D
€ 20 R&D hours wages sum sum withholding tax
on basis of on basis of on basis of credit (€)
actuals (€) actuals (€) actuals (€)
R&D Declaration 1 850 17.000 8.500 25.500 8.160
R&D Declaration 2 950 19.000 9.500 28.500 9.120
R&D Declaration 3 500 10.000 2.000 12.000 3.840
Total allocated R&D withholding tax credit € 21.120
Correction amount = € 26.496 - € 21.120 = € 5.376

10.2 Deduction of the R&D tax credit Wage Tax and National Insurance Contributions
for R&D taxpayers (self- (Reduced Remittances) Act (WVA).
employed persons)
You, as a self-employed person, may submit one or 10.3 Settlement of revised R&D
more applications a year and be issued one or more Declarations
R&D Declarations. Once you are granted a total of more
than 500 hours, RVO will issue you an R&D Declaration Once you have submitted your statement (see chapter
granting you an R&D tax credit. You can deduct this 11) of the actual number of R&D hours worked and any
R&D tax credit when you work more than 500 R&D actual costs and expenditures, RVO will issue a
hours on the projects approved by RVO. You may then revised R&D Declaration, taking into account all
deduct the R&D tax credit from your income tax return statements you submitted in the past calendar year.
for the year covered by your R&D Declaration(s).
The revised R&D Declaration specifies a single
correction amount for all the R&D Declarations in the
You must start recording your R&D hours from relevant calendar year. The correction amount is based
the date on which your application was on the statements you have submitted per R&D
submitted, or with effect from the calendar year Declaration. This amount is equal to the original (total)
if you submitted your application in the R&D withholding tax credit you were granted, less the
previous year. amount of withholding tax credit calculated based on
the actual number of R&D hours worked. An example
of this calculation is shown above, based on the fixed
The R&D tax credit reduces your profit (where ‘profit’ is sum approach.
understood as the balance of your turnover less your
costs, a balance that may then be negative). If your The manner in which you are required to settle the
taxable income in Box 1 is negative then you may carry correction amount depends on the amount of the R&D
the negative income back to the income in Box 1 in the withholding tax credit that you have already deducted.
three preceding calendar years and forward to the There are three alternatives:
following nine calendar years (see Article 3.150 of the
Income Tax Act, 2001). The actual R&D tax credit cannot 1. The amount of the R&D withholding tax credit you
be transferred separately to another financial year. have already deducted from your tax returns is
The regulations governing the R&D tax credit for exactly equal to the R&D withholding tax credit
selfemployed entrepreneurs are laid down in Article 3.77 granted in the revised R&D Declaration
of the Income Tax Act, 2001, in conjunction with

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You took account of the actual number of R&D hours you may apply an amount of the granted R&D
worked when you deducted the R&D withholding tax withholding tax credit, then you should deduct
credit. You do not need to settle any difference. the correction amount from this amount and
incorporate the remainder of the R&D
2. The R&D withholding tax credit deducted from withholding tax credit, whether this is a positive
your tax returns is more than the R&D or negative amount, in your tax return.
withholding tax credit granted in the revised R&D You incorporate this amount as a negative R&D
Declaration withholding tax credit into your payroll tax
If you have already deducted all or most of the original return for the period corresponding to the date
R&D withholding tax credit you were granted, then of the revised R&D Declaration, or for the
once you have received the revised R&D Declaration following tax return period.
you will need to reimburse the excess amount of the
R&D withholding tax credit that you deducted.
Example of a revised R&D Declaration:
Example of a revised R&D Declaration: excessive deduction of R&D withholding
excessive deduction of R&D withholding tax credit, costs and expenditures approach
tax credit, fixed sum approach You make an application for the whole of 2024
You submit a 2024 application for a total of 4,000 amounting to a total of 40,000 R&D hours.
R&D hours. The hourly wage for R&D work is set The R&D wage rate is € 25. You also choose to
at € 25. You have chosen the fixed sum approach. claim for a total of € 500,000 in costs and
In March 2024 you are issued with an R&D expenditures. In March 2024 you are given your
Declaration. R&D Declaration.

The R&D wage allocation is € 100,000 (4,000 hrs The allocated R&D wages amount to
x € 25/hr). € 1,000,000 (40,000 hours x € 25/hr). The total
The granted fixed sum is: (1,800 x € 10) + ((4,000 underlying amount on which the R&D
– 1,800) x € 4) = € 18,000 + € 8,800 = € 26,800 withholding tax credit is calculated is the sum
The total underlying sum on which the R&D tax of the R&D wage costs and other costs and
credit is based is: € 100,000 + € 26,800 = € 126,800 expenditures, and is therefore: € 1,000,000 +
The R&D tax credit granted is 32% of € 126,800 = € 500,000 = € 1,500,000. The granted R&D
€ 40.576. You deduct, in the months of March withholding tax credit is 32% of € 350,000 +
until December the full amount of the granted 16% of (€ 1,500,000 - € 350,000) = € 112,000 + €
R&D tax credit of € 40,576. 184,000 = € 296,000. From March until
At the end of the calendar year it turns out that a December, you should deduct the full amount
lower than expected total of 3,200 R&D hours have of the allocated R&D tax credit. You decide on
been achieved. You must report this to RVO by no the amount of the reduction for each period up
later than 31 March 2025. You will recieve from to the amount of the total payroll tax for that
RVO a revised R&D Declaration. period.

The actual R&D wage bill is: 3,200 x € 25 = € 80,000. At the end of the calendar year it turns out that
The fixed sum WBSO tax credit support is a total of 35,000 R&D hours were actually
therefore: (1,800 x € 10) + ((3,200 – 1,800) x € 4) = carried out, and that a total of € 425,000 has
€ 18,000 + € 5,600 = € 23,600. been spent on costs and expenditures. You
The actual underlying amount on which the actual have until 31 March 2025 to report this to RVO.
R&D tax credit is based is: € 80,000 + € 23,600 = You will recieve from RVO a revised R&D
€ 103,600. Declaration.
The actual R&D tax credit support is 32% of €
103,600 = € 33,152. The correction amount is The actual R&D wages are: 35,000 x € 25 =
therefore: € 40,576 - € 33,152 = € 7,424. € 875,000. The actual underlying sum with which
the R&D withholding tax credit is calculated is:
In your tax withholding return for the month of € 875,000 + € 425,000 = € 1,300,000. The actual
April or May 2025 you declare this correction R&D withholding tax credit is 32% of € 350,000
amount as a negative R&D tax withholding + 16% of (€ 1,300,000 - € 350,000) = € 112,000 +
amount. If you have been issued an R&D € 152,000 = € 264,000. The correction amount is
Declaration for 2025 and in April or May 2025 therefore € 296,000 - € 264,000 = € 32,000.

40 I 2024 WBSO Manual

 In your tax withholding return for the month of Example of a revised R&D Declaration:
April or May 2025 you declare this correction R&D withholding tax credit still to be claimed
amount as a negative R&D tax withholding In August 2024 you receive your R&D
amount. If you have been issued an R&D Declaration from July until December 2024.
Declaration for 2025 and in April or May 2025 You have been granted an R&D withholding tax
you may apply an amount of the granted R&D credit of € 50,720. You pay payroll tax of
withholding tax credit, then you should deduct € 11,000 a month and you have decided to
the correction amount from this amount and deduct € 4,000 of the R&D withholding tax
incorporate the remainder of the R&D credit in each of the months of August to
withholding tax credit, whether this is a positive December 2024 inclusive.
or negative amount, in your tax return.
No later than 31 March 2025 you report to RVO
that your records reveal a total of 3,200 R&D
3. The R&D withholding tax credit already deducted hours worked.
from your payable tax is less than the R&D
withholding tax credit granted in the revised R&D In April 2025 you receive a revised R&D
Declaration Declaration from RVO. The correction amount is
If you have not yet deducted the R&D withholding tax € 9,280.
credit or you have deducted less than the R&D
withholding tax credit you are entitled to, based on the You have already deducted 5 x € 4,000 =
actual number of R&D hours worked, then, once you € 20,000 in the period covered by the R&D
have received the revised R&D Declaration, you can Declaration. You are therefore still entitled to
deduct the remainder of the R&D withholding tax € 41,440 - € 20,000 = € 21,440 unused R&D
credit. In order to settle the allowed tax credit, you withholding tax credit. You can, for instance,
submit one or more correction messages for the settle this in your April 2025 tax return with
expired tax periods within the calendar year to which correction messages for the months of
the R&D Declaration applies. Understandably, you can November and December 2024, each of
never deduct more R&D withholding tax credit than the € 10,720, or with an € 11,000 correction message
withholding tax payable in a given tax period. for July 2024 and a € 10,440 correction message
Correction messages are part of your payroll tax return. for August 2024.

In this instance you do not need to delay the

settlement until you receive the revised R&D
Declaration from RVO. In principle you could
also deduct the remaining amount of the tax
credit from the tax return for December 2024,
for example by deducting € 11,000 instead of
€ 4,000 in this month, and by submitting a
correction notice, for example, for September,
October, November 2024 for a total amount of
€ 14,440 (e.g. for € 440, € 7,000 and € 7,000
respectively). However, you are still under the
obligation to submit a statement to RVO in time!

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 11. How do you make a
statement?
This chapter explains how and when you must make a
statement of the number of R&D hours actually Please take the following into consideration when
worked and the costs and expenditures actually stating costs and expenditures:
incurred. • the actual costs and expenditures you state must have
been paid at the time you submit the statement;
• you may only state the costs and expenditures that you
11.1 Statement have included in the application and that RVO has
allocated;
If you are an R&D tax withholding agent you are obliged • you should only state the actual costs that you have
to submit a statement to RVO of the number of hours incurred and paid for your R&D activities. The costs
you have actually devoted to R&D in a given year and, are incurred the moment you incur them for your
where relevant, the costs and expenditures thereby R&D work. If you have already purchased materials
incurred. If you are an R&D taxpayer you must submit a that you have paid but have not yet used for your R&D
statement to RVO if fewer than 500 hours were actually activities, this means that you cannot include these
devoted to R&D. This section explains the procedure costs in the statement.
involved in making this statement.
After the end of the calendar year covered by your R&D
Please find detailed information about submitting a Declaration(s) RVO will send you an email reminding
statement on www.rvo.nl/wbso/realisatie-melden. you of your obligation to submit this statement. If an
R&D Declaration was issued after the end of the calendar
Use the calculation tool and the explanatory notes to the year covered by the R&D Declaration, you must submit
calculation tool (PDF) as an aid to help you accurately the statement within three months of the date of the
report the actual hours incurred as well as costs and R&D Declaration. Make sure that you submit your
expenditure. Our ‘Handleiding mededelen WBSO’ statement to RVO in time.
(WBSO statement manual) (PDF) includes examples on RVO will impose a fine if you submit an incorrect
transferring hours, costs and expenditure as well as a statement or do not submit a statement in time. You are
clear step-by-step plan. under the obligation to submit a statement even if you
have not carried out any R&D work and have not
Statement by R&D tax withholding agents deducted the R&D withholding tax credit. If, after a
You are obliged to make a statement of the number reminder, you still fail to submit a statement the number
of R&D hours you have actually achieved. If your R&D of R&D hours worked will be set at 0. This will result in
Declaration was issued on the basis of costs and the full correction of your R&D Declaration and the
expenditures, then you must also report the actual costs imposition of a fine.
and expenditures incurred. If the number of R&D hours
actually achieved is equal to, or greater than,
the number of R&D hours specified in your R&D If you have received one or more R&D
Declaration, and if the total actual costs and expenditures Declarations for 2024, then you submit a single
are greater than the amount specified for costs and statement of the actual number of R&D hours by
expenditures in your R&D Declaration, then you may no later than 31 March 2025. Your statement
deduct the granted R&D withholding tax credit in full, as specifies the actual number of R&D hours
described in section 10.1. worked and the costs and expenditures incurred.
If you have elected the fixed sum approach, then
You submit one statement for all the R&D Declarations you need only report the number of R&D hours
you were issued by no later than three months after actually carried out.
the end of the relevant calendar year. Your statement
specifies the actual number of R&D hours worked and,
where relevant, the costs and expenditures incurred.
This statement must be made.

42 I 2024 WBSO Manual

 Business closure or bankruptcy? between Project A and Project B. In addition, within the
Are you forced to terminate your business? same calender year, you may also use unrealized R&D
Please inform us as soon as possible by e-mail: hours (and any unrealized amounts of approved costs
[email protected]. We will immediately enable the and expenditures) for an approved project from previous
option to make the mandatory statement in the R&D Declarations for approved projects from later R&D
application portal. You are obliged to make the Declarations.
mandatory statement within 1 month after the
closure date. Please note!
You can never transfer costs between R&D hours on the one hand and
costs and expenditures on the other. You can transfer unrealized R&D
Statement if your company no longer acts as a hours (and amounts for allocated costs and/or expenses)
withholding agent to allocated projects (and allocated costs and/or expenses) for which
If your company stopped acting as a withholding agent you applied at a later date. Moving back to an earlier period is not
in the calendar year covered by your R&D Declaration, allowed. The total number of hours claimed may also never exceed the
you must submit a statement of the actual number of number of hours on which your R&D Declaration is based.
R&D hours worked within one month of the date on
which your company stops acting as a withholding Please note!
agent. If you fail to make this statement, or make it too You may only state costs and expenditures that (exclusively) serve the
late, RVO will impose a fine. execution of and are directly attributable to the R&D project. You may
only state the costs and expenditures that you have included in the
Statement to be made by R&D taxpayers application and that RVO has allocated. This applies per project, not per
(self-employed persons) application.
If your actual number of R&D hours worked in a calendar
year is less than 500, you must submit a statement to Please note!
RVO within three months of the end of that calendar In your statement, please take into account the attribution of an item of
year. RVO will then revoke your R&D Declaration(s). The expenditure. The attributable portion of the expenditure must be
R&D tax deduction that you were granted earlier will be objectively ascertainable and serve the purposes of the R&D. You will
withdrawn. You will no longer be permitted to deduct need to substantiate this calculation in your R&D records.
the R&D tax credit for self-employed persons from your
income tax return. After the end of the calendar year
covered by your R&D Declaration(s) RVO will send you a Statement submission tools
email reminding you of your obligation to submit a There are a number of handy tools that you can
statement. This reminder includes a password that you use to submit the information required. When
can use to submit your statement. preparing your statement, use:
• the Stappenplan mededelen WBSO (WBSO
statement submission step-by-step plan) (PDF)
11.2 Actual hours, costs and • the calculation tool and explanation of the
expenditures calculation tool (PDF) to calculate your total
actual hours and possible costs and
If your application was submitted for a number of expenditures.
projects, it is conceivable that the actual R&D hours • the Handleiding mededelen WBSO (WBSO
worked on each project vary from the estimated hours submission manual) (PDF) containing
on which your application was based. You are permitted frequently asked questions and examples of
to transfer R&D hours between the projects approved in how to transfer hours, costs and expenditures.
a single R&D Declaration. You may also transfer the You will be able to find these publications on
approved amount of costs and expenditures between www.rvo.nl/wbso/realisatie-melden as of the
projects within a single R&D Declaration. If, for example, beginning of 2024.
the actual R&D hours worked on a project are lower than
estimated, you may transfer the remaining hours for that
project to one or more other R&D projects that require
more time. For instance, if a machine intended for
Project A was budgeted at € 900,000 but actually cost
only € 800,000, while the cost of materials required for
Project B had been estimated at € 200,000 but ended up
costing € 300,000, then € 100,000 may be transferred

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 12. Inspection
The Netherlands Enterprise Agency (RVO) supervises • costs and/or expenditures that have not been requested
compliance with all the conditions attached to the are registered;
WBSO. RVO therefore conducts retrospective • R&D hours (and costs and/or expenditures) are
inspections. These may be desk inspections or registered for activities that are excluded from the
on-site inspections at your company. This chapter WBSO;
explains inspections in more detail. • R&D hours of workers that are not on the company’s
payroll have been registered.

12.1 Retrospective inspections RVO may, depending on the omission, supplement a

by RVO correction with the imposition of a fine. The correction
can be no more than the R&D withholding tax credit
If you have been issued an R&D Declaration, RVO may awarded in the original R&D Declaration. Any fine
carry out a retrospective inspection to verify that the RVO imposes will be included in the revised R&D
information specified in your application is in Declaration. You enter the excess amount of the R&D
agreement with the actual situation and that you comply withholding tax credit, increased by the fine where
with the statutory requirements. RVO inspects the R&D relevant, as a negative R&D withholding tax credit in the
work you carry out and the time you spend on R&D tax return for the tax period in which the revised R&D
against your R&D administrative records. If you made a Declaration was dated or for the next tax period.
claim for actual costs and expenditures, then RVO will
also inspect which costs and expenditures have been
incurred and paid for in connection with the R&D work 12.3 Objections and appeals
covered by the R&D Declaration you were issued.
You may lodge an objection against a revised R&D
The inspection of the Dutch Tax Authorities is restricted Declaration you have been issued by submitting a notice
to your tax returns and to the correct deduction of the of objection to RVO which states the reasons for your
amounts specified in your R&D Declaration. objection. You can read in your decision how you may
submit a notice of objection. If you are unable to agree
with RVO’s decision on your notice of objection, you can
12.2 WBSO corrections and fines then lodge an appeal with the Trade and Industry
Appeals Tribunal. RVO will draw your attention to the
Use of the WBSO is subject to compliance with a number opportunity to lodge an objection or appeal in its
of conditions and administrative requirements. decisions. Neither an objection nor an appeal procedure
Experience has revealed that errors are occasionally discharges you from your obligation to settle the revised
made. RVO will issue a revised R&D Declaration when for R&D Declaration.
example an inspection reveals that:
• you have not fulfilled your administrative obligations If you have lodged an objection against a fine imposed
or have not fulfilled them in time; on you and you are unable to agree with RVO’s decision
• it is plausible that you submitted information or on your notice of objection, you can lodge an appeal
documents that was or were incorrect or incomplete with the district court of Rotterdam rather than the
so that you would be issued an R&D Declaration and Trade and Industry Appeals Tribunal. If you lodge an
RVO would have reached a different decision if the appeal, the Trade and Industry Appeals Tribunal is
correct information had been known in full at the competent to reach a decision on your appeal. RVO will
time of the assessment; draw your attention to the opportunity to lodge an
• you have submitted an incorrect statement of the objection or appeal, and to the periods in which you
actual number of R&D hours worked and, where must lodge an objection or appeal. RVO is authorised to
relevant, of the actual costs and expenditures incurred; impose fines in such cases.
• you have provided incorrect citizen service numbers
(bsn’s) for the determination of the R&D hourly wage;
• R&D hours are registered on projects that have not
been allocated;

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13. Checklist
Obligations checklist
Provide the appropriate citizen service numbers (bsn’s).

If you applied for a WBSO tax credit in 2022, we will calculate your R&D hourly wage for 2024 on the
basis of the wage data of the employees at your organisation who carried out R&D activities in 2022.
• Only provide the bsn’s of employees who carried out R&D activities, not the bsn’s of administrative and
organisational employees.
• Provide the bsn’s of R&D employees from the appropriate year. These R&D employees have to be
registered in your R&D time sheet administration for 2022.
• If you did not use the WBSO in 2022, there will be no need for you to provide any bsn’s.
The standard R&D hourly wage of €29 will apply for you in this situation.

Further information
www.rvo.nl/wbso/bsnmelden

Submit the actual number of R&D hours worked and any costs and expenditures incurred.

You must submit your R&D hours and any costs and expenditures incurred in the previous year to us
before 31 March. There are a number of handy tools that you can use to submit the information required.
You can find these publications on www.rvo.nl/wbso/realisatie-melden.

Keep good R&D administrative records.

Time sheet administration

• Do not record R&D hours worked by trainees, graduate students or others not on the payroll.
• Do not record R&D hours for organisational and administrative activities.
• Do not record R&D hours for projects for which you have not received an R&D declaration.
• Do not record R&D hours during the period of an employee’s leave of absence or sick leave.
• Record R&D hours per person, per day and per project.
• Make sure that the activities carried out correspond with the projects approved by RVO.

Project administration
• Keep records that provide a clear overview of the nature, content and progress of R&D activities per
R&D project.

Administration of costs and expenditures

• Retain (digital) documents like quotations, order confirmations, invoices and receipts.
• Record costs and expenditures per project.
• Only record costs and expenditures that have been allocated.
• You may only include the costs and expenditures in your administrative records that you submitted as
part of your application and that the RVO has allocated.

Further information
• Chapter 9 of the WBSO Manual
• You’ve submitted an application. What happens next (PDF) on www.rvo.nl/wbso > Publicaties.
• www.rvo.nl/wbso > Na uw WBSO-aanvraag > S&O-administratie bijhouden (R&D administration). You will
also find a number of Excel templates that you can use to record hours, costs and expenditures.

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Obligations checklist
If you have applied for WBSO for costs and/or expenditures, consider the following.

If you partially include expenditures under the WBSO, demonstrate how you arrived at your calculations in
your R&D administrative records. This calculation must be substantiated based on actual registrations. An
estimate will not be approved.
The part of the expenditure that is eligible is measured from the date of commission of the operating asset
until the end of the calendar year.

Do not specify any costs that are excluded by law. For example:
• the costs of hiring labour (temporary employees, for example);
• the costs of outsourced research;
• depreciation costs, financing costs;
• costs and expenditures for an R&D project that has not been approved/granted.

Only specify costs that exclusively serve the performance of and are directly attributable to the R&D
project. The phrase ‘exclusively serve the performance of and are directly attributable’ means that:
• you incur costs solely (100%) for the R&D project;
• there is a clear relationship between the costs specified and the R&D activities carried out.
If you would incur (part of these) costs even if you are not carrying out the R&D project, these costs are not
fully attributable to your innovation project and will not be eligible for the WBSO.

Please take the following into consideration when submitting costs and expenditures:
• the actual costs and expenditures you submit must have been paid at the time you report them;
• you may only include the costs and expenditures that you submitted as part of your application and that
RVO has allocated. This applies to each project rather than to each application.
• you should only submit the actual costs that you have incurred and paid for your R&D activities.
The costs are incurred the moment they are incurred for your R&D work. If you have already purchased
materials that you have paid but have not yet used for your R&D activities, this means that you cannot
include these costs in the statement.

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 14. Calendar
Who is it
Important dates What? important
for?*
20 December 2023 final date to apply for the WBSO as of 01/01/2024 1

• start of R&D year

1 January 2024 1 and 2
• keep R&D administrative records (from the start of the application period)

date on which self-employed persons can submit an WBSO application with

1 January 2024 2
start date 01/01/2024
final date to apply for the WBSO for a maximum of
31 Januray 2024 1
11 months (February - December)
final date to apply for the WBSO for a maximum of
28 February 2024 1
10 months (March-December)
final date to submit:
• the actual R&D hours worked in 2023
31 March 2024 1
• the actual costs and expenditures incurred in 2023
(if included in the application)
final date to apply for the WBSO for
31 March 2024 1
9 months (April - December)

31 March 2024 final date to submit the fact that < 500 R&D hours were worked in 2023 2

final date to apply for the WBSO for 8 months

30 April 2024 1
(May - December)

31 May 2024 final date to apply for the WBSO for 7 months (June-December) 1

final date to apply for the WBSO for 6 months

30 June 2024 1
(July - December)

31 July 2024 final date to apply for the WBSO for 5 months (August-December) 1

31 August 2024 final date to apply for the WBSO for 4 months (September-December) 1

final date to apply for the WBSO for 2024 1 and 2

30 September 2024 final date to apply for the WBSO for 3 months
(October-December)
20 December 2024 final date to apply for the WBSO as of 01/01/2025 1

31 December 2024 end of R&D year 1 and 2

*) 1. companies with employees (for example, a private limited company or public limited company)
2. self-employed workers without employees
If you are a self-employed worker with employees, the dates for companies with employees will apply
for your employees (1). E.g. For all self-employed workers without employees: The application period starts from the date that you
submit the application untill the end of the calendar year.

47 I 2024 WBSO Manual

 15. Glossary
AI will not be granted. The decision to refuse an
Artificial Intelligence application is also a Decision.

API eRecognition token

Application programming interface An eRecognition token is a digital key that you can use
to identify yourself easily to various government service
BSN providers. It is comparable to internet banking, when
The Dutch ‘citizen service number’. RVO uses the bsn’s you confirm an action with a code (which you receive
of your R&D employees to calculate the R&D hourly via SMS) or a token. You need an eRecognition token to
wage. You can submit bsn’s simply via the internet. gain access to eLoket.
When a WBSO Declaration is issued to a self-employed
person, this also states the self-employed person’s bsn. Expenditures
This self-employed person may deduct the R&D tax If you are an R&D tax withholding agent, you can elect
credit from their income tax return. to claim against the costs and expenditures you expect
to incur in carrying out your own research and develop-
Correction message ment. ‘Expenditures’ here is understood as all the
Correction messages are part of the payroll tax return payments made in procuring newly-manufactured
and are intended for the revision of tax returns filed at operating assets, to the extent that these are borne by
an earlier date. Correction messages also enable you to the R&D tax withholding agent or by a company from
deduct unused R&D withholding tax credit in all tax within the same tax entity. In addition, the operating
periods of the calender year to which you assets may not have been used before, may not have
R&D-declaration applies. You can file correction been included in a previous R&D Declaration, and must
messages with the Dutch Tax Authorities. be for the sole purpose of in-house research and
development work.
Costs
If you are an R&D tax withholding agent, you can elect Hourly criterium
to claim WBSO support for the costs and expenditures Hourly criterium as mentioned in article 3.6.1 of the
you expect to have to pay in carrying out your own R&D Income Tax Act 2001 (Wet Inkomstenbelasting 2001).
work. ‘Costs’ are understood as all the payments you
need to make in carrying out your research and Operating asset
development work and not qualify as expenditure. An asset used in conducting a business.
The payments must serve solely for the purpose of the
performance of the in-house R&D, must be borne by Outsourced research
the withholding taxpayer or by a company from within Work deemed to be the taxpayer’s research and
the same tax entity, and may not have been mentioned development work that the taxpayer outsources to a
in an earlier R&D Declaration. Costs must have been third party. The costs of outsourced research do not
paid before you are entitled to include them as actual come into consideration for WBSO support.
incurred payments in your mandatory statement.
Payroll tax
Decision Payroll tax is an advance levy of an employee’s wage
The document that RVO provides to give notification of tax and national insurance contributions. The Dutch
its decision on an application for WBSO support. The Tax Authorities is responsible for the levy of wage tax
WBSO Decision specifies the number of R&D hours that and national insurance contributions. Wage tax and
have or have not been allocated to each project national insurance contributions are often jointly
specified in the application. If R&D hours are allocated, referred to as ‘payroll tax’ as they are withheld by the
an R&D Declaration will be enclosed on a further page. employer and paid to the Dutch Tax Authorities.
If a withholding agent has elected not to apply on the
basis of a fixed sum approach, then the Decision will
also specify which costs and expenditures will and/or

48 I 2024 WBSO Manual

 Payroll tax number R&D
Withholding agents are issued a payroll tax number by Research and Development work: systematically-organised
the Dutch Tax Authorities. The number consists of an work activities carried out by an R&D tax withholding agent
RSIN and a sub-number. A withholding agent usually or an R&D taxpayer in a Member State of the European
consists of one accounting entity. This is usually Union, whose direct and exclusive purpose is:
indicated by ‘01’ (sub-number) following the ‘L’ in the 1. technical scientific research;
payroll tax number. 2. the development of (parts of ) physical products,
physical production processes, or software that are
Public knowledge institute technically new for the R&D tax withholding agent or
If your organisation is a public knowledge institute you the R&D taxpayer.
are not eligible for WBSO support. A ‘public knowledge
institute’ is held to mean: R&D administrative records
1. an institute of higher education, as listed in The administrative records holding details of the nature,
subsection a, b, c, g, h and i in an Appendix of the content, progress in and scope (allocation of the time)
1992 Higher Education and Research Act (Wet op het of the R&D work, and where relevant of the costs and
hoger onderwijs en wetenschappelijk onderzoek) or expenditures incurred and paid. You must keep these
an academic hospital as listed in subsection j of the records if you wish to make use of the WBSO.
same Appendix;
2. a research organisation that is either wholly or partly R&D Declaration
publicly funded on a multiannual basis, which A Declaration issued to you by RVO. The R&D Declaration
carries out activities with the aim of expanding for an R&D tax withholding agent states the maximum
general scientific or technological knowledge; amount of R&D payroll tax credit that can be deducted
3. a public institute of higher education, academic from your payroll tax return (whose ID number is
hospital, or research organisation, structurally part- specified in the Declaration) in the calendar year to which
funded or wholly funded by another Member State of the R&D Declaration applies. An R&D taxpayer must carry
the European Union, equivalent to a public out 500 hours of R&D to be eligible for an R&D
knowledge institute as defined in 1° or 2°. Declaration, which entitles them to deduct the R&D tax
credit from their income tax return. The R&D Declaration is
Research organisation sent to the applicant together with the relevant Decision.
A research organisation as defined in Article 1.3, part
(ee) of the Framework for State aid for research and R&D withholding tax credit
development and innovation (Kaderregeling The WBSO enables the R&D tax withholding agent
betreffende staatssteun voor onderzoek, ontwikkeling to deduct a tax credit from the payroll tax, thereby
en innovatie, OJEU 2014, C198/7). Such organisations reducing the amount of payroll tax to be paid. This
may be designated as public knowledge institutes, deduction from the payroll tax to be paid is referred
which are ineligible for WBSO support. to as the ‘R&D withholding tax credit’.

Revised R&D Declaration R&D tax credit

A revised R&D Declaration is a revision of an R&D The amount that a self-employed person can declare as
Declaration issued on an earlier date. RVO issues you a a deduction in their income tax return if they possess an
revised R&D Declaration after you have submitted a R&D Declaration and carry out at least 500 R&D hours in
statement or after an RVO inspection has revealed that a the calendar year concerned. The R&D tax credit is
correction is required. The revised R&D Declaration defined in Article 3.77 of the Income Tax Act 2001.
specifies the amount by which the R&D withholding tax
credit has been corrected. Depending on the amount of R&D tax payer
the R&D withholding tax credit that you have already A natural person who conducts a business within the
deducted, you will either be entitled to deduct a further meaning of the Income Tax Act and who meets the
portion of the credit or be required to reimburse the hourly criterium as mentioned in article 3.6.1. of the
excess amount of the R&D withholding tax credit that Income Tax Act 2001 (Wet Inkomstenbelasting 2001).
you have deducted. Information about this is enclosed
in the revised R&D Declaration. Any correction amount R&D tax withholding agent
is settled in your payroll tax return. A tax withholding agent who runs a company that is
not a public knowledge institute and possesses an R&D
Declaration.

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 R&D wages Self-employed persons must have been an entrepreneur
R&D wages are the wages paid for research and for a maximum of four out of the past five years and
development work. The R&D wages = number of R&D received R&D Declarations in a maximum of two years to
hours x R&D hourly wage. be regarded as start-up entrepreneurs. When the R&D
activities of another company are continued and the
R&D hours self-employed person holds a substantial interest in that
R&D hours are the hours spent on R&D work. other company, then the calendar years in which that
other company has received R&D Declarations are taken
R&D hourly wage into account in the determination of the start-up status
The R&D hourly wage is the total of the wages of R&D of the self-employed person submitting the application.
employees / (0.85 x total hours paid for all R&D employees).
The factor 0.85 serves as compensation for leave. The result Start-up facility
is rounded up to the nearest € 1. The calculated hourly The WBSO offers additional support for start-up
wage is always applicable to a full calendar year. companies and entrepreneurs. This is referred to as the
RVO calculates the R&D hourly wage on the basis of the ‘start-up facility’.
submitted BSNs of employees who carried out R&D
work two years ago. If the R&D hourly wage cannot be Statement
calculated, the standard hourly wage is applicable. If you are an R&D tax withholding agent, at the end of a
calendar year you must always submit a report to RVO
RSIN that specifies the actual number of hours you have spent
The ‘Legal Persons and Joint Operations Information on research and development in that calendar year, as
Number’ (Rechtspersonen en Samenwerkings­verbanden well as – where applicable – the costs and expenditures
Informatienummer) of the R&D tax withholding agent. that were incurred and paid. This is referred to as
The RSIN forms part of your payroll tax number. ‘submitting a statement’. If you are an R&D taxpayer
(a self-employed person), you are required to make this
Software statement only if you have carried out less than 500 hours
The non-physical, logical subsystem of an information of R&D work in that year. The statement is submitted via
system that determines the structure of the data and its the internet, at mijn.rvo.nl/wbso.
processing to the extent that this subsystem is fixed in a
formal programming language. Supply chain authorisation
Supply chain authorisation allows organisations to
Standard hourly wage authorise other organisation to make use of an online
The standard hourly wage is a hypothetical hourly wage service using eHerkenning on their behalf.
applicable to applicants for whom the R&D hourly Intermediaries and agents submitting WBSO
wage cannot be calculated. The standard hourly wage is applications on behalf of another party will need
set once a year and amounts to € 29 in 2024. supply chain authorisation at EH3 Level. Please find
more information on supply chain authorisation on
Start-up company or entrepreneur www.eherkenning.nl/ketenmachtiging.
A start-up company is an applicant who has employed
personnel for a maximum of four out of the past five Tax entity
calendar years and has been issued R&D Declarations in a A tax entity is comprised of a number of companies
maximum of two years. If a company continues the that are jointly regarded as one company. The Dutch
activities of another company and is affiliated with that Tax Authorities issues a tax entity declaration. A tax
other company, then the calendar years in which that entity often consists of a parent company and one or
other company has received R&D Declarations are taken more subsidiaries. Companies can form a tax entity for
into account in the determination of the start-up status a variety of types of tax. The existence of a tax entity for
of the taxpayer submitting the application. corporate income tax purposes is the sole form of tax
entity of relevance to the WBSO.

50 I 2024 WBSO Manual

 TSR
TSR stands for ‘technical scientific research’.

WBSO
WBSO stands for the Research and Development
Promotion Act (Wet Bevordering Speur- en
ontwikkelings­werk). It is a tax incentive scheme
introduced by the Dutch government to compensate part
of the wage and other costs and expenditures incurred in
carrying out research and development (R&D).

The WBSO no longer formally exists as a separate Act,

but has been subsumed into Chapter 8 of the Wage Tax
and National Insurance Contributions (Reduced
Remittances) Act (WVA).

Withholding agent
When you pay wages to an employee or a benefit to a
person entitled to a benefit then you are required to
withhold wage tax and national insurance
contributions (jointly also referred to as payroll tax)
and pay the withheld amount to the Dutch Tax
Authorities. If you are required to withhold and pay
payroll tax in this way, you are referred to as a
‘withholding agent’.

51 I 2024 WBSO Manual

 WBSO Innovation Box
The WBSO is an initiative of the Ministry of Economic Affairs and The Innovation Box is intended to provide entrepreneurs a tax
Climate Policy which helps companies to reduce the costs of their incentive for innovative research. The Dutch Tax Authorities
R&D. The scheme is implemented by RVO, part of the Ministry of implement the Innovation Box. An R&D Declaration is a required
Economic Affairs and Climate Policy. Companies can deduct the access pass for the Innovation Box. On www.rvo.nl/wbso under the
financial benefits of WBSO from the payroll tax they pay to the menu ‘Publicaties’ you will find a detailed brochure about the
Dutch Tax Authorities. Innovation Box (only in Dutch).
www.rvo.nl/wbso

Contact Patents
Telephone +31(0)88-0424242 (on workdays from 8.30am till 5pm). The Netherlands Patent Office (NL Octrooicentrum) provides
You can also call this number if you have any questions about information on intellectual property rights as well as relevant
making submissions via mijn.rvo.nl/wbso. patent information with which to further develop your invention,
identify competitors, and find potential partners.
Financial settlement www.rvo.nl/octrooien
If you have any questions about the deduction of the WBSO, contact
the Tax Information Line (tel. 0800 0543 in the Netherlands) or your
company’s tax office.

This is a publication of: Other schemes that may be of interest

Netherlands Enterprise Agency (Rijksdienst voor Ondernemend
Nederland) Energy Investment Allowance (Energie Investeringsaftrek, EIA)
Hanzelaan 310 Benefit from tax advantages when investing in energy-saving
8017 JK Zwolle systems and technologies and in sustainable energy supplies.
Postbus 10073 | 8000 GB Zwolle www.rvo.nl/EIA
T +31 (0) 88 042 42 42
www.rvo.nl Environmental Investment Allowance (Milieu Investeringsaftrek,
MIA) and Vamil
© Netherlands Enterprise Agency | January 2024 Benefit from tax advantages when investing in environmentally-
friendly systems and technologies. www.rvo.nl/miavamil
Publication number: RVO-001-2024/HL
Innovation credit (Innovatiekrediet)
The Netherlands Enterprise Agency (RVO) assists entrepreneurs in Credit for the financing of highly promising and innovative
sustainable, agrarian, innovative and international business projects. www.rvo.nl/innovatiekrediet
ventures through subsidies, the identification of business partners,
knowledge, and compliance with laws and regulations. Loans for SMEs (BMKB)
The Netherlands Enterprise Agency is part of the Ministry of Bank loans for small and medium-sized enterprises, with favourable
Economic Affairs and Climate Policy. conditions. www.rvo.nl/bmkb

Although this publication has been prepared with the greatest Other support for entrepreneurs
possible care, the Netherlands Enterprise Agency cannot accept any www.rvo.nl/ondernemersfinanciering
liability for errors it may contain. No part of this publication may be
reproduced and/or published by means of print, photocopy,
microfilm, electronically on tape or by any other means without
prior written permission from the publisher.