Dutch Box 3 reform: actual return taxation planned from 2028

Country reference

• Country: Netherlands (planned expansion country)
• Authorities: Ministry of Finance; Netherlands Tax Administration (Belastingdienst)
• Topic: Taxation of savings and investments (Box 3)
• Key date: Transitional system to 2027; new system targeted for 1 January 2028
• Law: Box 3 Actual Return Act (Wet werkelijk rendement box 3), pending in the Senate

Where things stand

• The House of Representatives adopted the Actual Return Act in February 2026; it is before the Senate.
• The target start date is 1 January 2028, and the Finance Minister has said amendments are expected.
• Until then, a transitional system applies: a 36% rate on a deemed return, with an exemption of EUR 59,357 in 2026.
• Following the Supreme Court, taxpayers can show their actual return was lower than the deemed return.

Budget Day 2026 proposals

• Rate from 36% to 35% and tax-free return threshold from EUR 1,800 to EUR 1,900, with a one-year carry-back of negative returns, in a separate bill expected for 2028, according to CMS.
• The government will present proposals to move part of the system towards a capital gains model at the next budget decision point.

Why it matters

• Under an actual return system, unrealised gains on some assets could be taxed each year, which affects liquidity.
• Residents with large portfolios, crypto or property outside their home are most affected.
• Expats and returning residents need to plan the timing of moves and asset sales.

What to do now

• Track the Senate vote and any amendments.
• Keep records of actual returns for 2026 and 2027 to support objections under the current system.
• Review whether assets are better held privately, in a company or abroad, with advice.

Our take

Box 3 has been unstable for years and the 2028 date may move again. For internationally mobile investors considering the Netherlands, it is the biggest open question.