Energyreduction certificates and taxation: letter to the Tax and Customs Administration regarding the tax treatment of reimbursements

More and more private individuals and companies are receiving payments related to emission reduction certificates, also known as ERE certificates. These certificates are traded on the market, and the proceeds are paid out via a bookkeeping service provider to the owner of, for example, an electric car, solar panels, or a charging station.

But what about the taxation of these payments? There is currently insufficient clarity on this matter. For this reason, a formal request for tax clarification has been submitted to the Tax and Customs Administration in Utrecht.

The goal: to obtain a written understanding of the Tax and Customs Administration's view on the payment of payments from the sale or trade of ERE certificates. Do you want to know which bookkeeping service providers are currently active? Then check out our comparison tool.

The letter requests a written explanation regarding the tax treatment of fees paid out by a bookkeeping service provider. The fee may relate to ERE certificates, but also to energy-related services such as electricity feed-in, charging services, or the settlement of charging sessions.

Specifically, the Tax and Customs Administration has been asked to provide an opinion on five points:

1. Private individuals (non-entrepreneurs) Is the fee from ERE certificates subject to income tax? If so, under which category — for example, result from other activities or income from savings and investments? And how should this be processed in the tax return?

2. SMEs and sole proprietors Does the fee qualify as business revenue? What points of attention apply regarding the timing of receipt, cost offsetting, and the tax treatment of recharged costs?

3. Companies and legal entities (such as energy suppliers and CPOs) How should the fee be processed within corporate income tax? Is it classified as turnover, revenue, or offsetting, and when must it be included?

4. Turnover Tax (VAT) Does the payment qualify as consideration for a service, and does this result in VAT implications? Consider possible exemptions, the place of supply, and invoicing requirements — depending on whether the recipient is a private individual or a business.

5. Withholding obligation and reporting obligations Does the bookkeeping service provider have a withholding obligation? And are there specific annual statement or reporting obligations towards the recipient or the Tax and Customs Administration?

If you receive reimbursements from ERE certificates — whether you are a private individual with an electric car, a business owner with charging stations, or an energy supplier — it is important to know how to process this income for tax purposes.

Currently, there is no clear position from the Tax and Customs Administration, and that is precisely why this request has been submitted. The Tax and Customs Administration has been asked to respond with a written explanation that can be used for the proper setup of your administration and reporting obligations.

As soon as a response is received, we will publish it on ERE-vergelijk.nl so that you know exactly where you stand. Are you considering switching accounting service providers in the meantime? Then read our article on switching accounting service providers mid-term.

Regardless of the Tax and Customs Administration's final decision, it is wise to start looking now at which bookkeeping service provider offers the best terms. Commissions in the market are falling rapidly — from an average of 25% in February 2025 to 15% at some providers.

Compare bookkeeping service providers and discover which party yields the most for your ERE certificates.

Do I have to pay tax on my ERE compensation?
That is not yet entirely clear at this moment. A letter has been sent to the Tax Administration requesting them to take an official position on this matter. As soon as we receive a response, we will publish it on our website.

Under which tax category does the compensation for private individuals fall?
That is exactly what we have asked the Tax and Customs Administration. Possible categories are income from other activities or income from savings and investments. The final answer will follow as soon as the Tax and Customs Administration responds.

Does VAT apply to ERE compensation?
This point has also been submitted to the Tax and Customs Administration. Whether the payment is classified as a VAT-taxable transaction depends on several factors, including whether you are a private individual or an entrepreneur.

What are ERE certificates?
ERE certificates (emission reduction certificates) are tradable certificates representing the CO₂ reduction from, for example, electric driving or the generation of green energy. You can monetize these certificates via a bookkeeping service provider. Can I switch to another bookkeeping service provider?

Yes, but not within the current fiscal year. Read more in our article on Switching mid-term, is that possible?

Where can I find the best bookkeeping service provider?
On ERE-vergelijk.nl, we compare all recognized bookkeeping service providers based on commission percentage, terms and conditions, payout speed, and transparency.