Update on Dutch personal income tax on savings and investments (box 3).

March 4, 2026

The Dutch government is progressing with a fundamental redesign of box 3 (taxation of savings and investments) in the personal income tax. The current system largely relies on deemed (notional) returns rather than the taxpayer’s actual return. Following repeated court scrutiny of outcomes where taxation exceeds actual return, the government aims to introduce a new “actual return” regime as of 1 January 2028.

The Wet werkelijk rendement box 3 is a hybrid system. As a main rule, a vermogensaanwasbelasting applies meaning annual taxation on regular income (e.g., interest, dividends, rent) and (un)realized value changes for most asset categories. For real estate and shares/profit rights in start-ups, a vermogenswinstbelasting applies instead. Taxation is triggered on realization (e.g., sale) of the asset. Under the bill, losses can be carried forward, but no carry-back is included.

Although this new tax has already passed the House of Representatives (Tweede Kamer) and is now up for review at the Senate (Eerste Kamer), the Minister of Finance announced last week Thursday that the vermogensaanwasbelasting must be adjusted. The vermogensaanwasbelasting faced criticism because it taxes unrealized gains, which for taxpayers could result in liquidity problems when paying the tax, forcing them to sell assets only to pay the tax. Whether or not the vermogensaanwasbelasting will be abolished altogether in favor of the vermogenswinstbelasting remains to be seen. The House of Representatives has requested to adopt a carryback of losses for a period of one year.

We will periodically update you on the saga of the box 3 tax in the Netherlands as this develops.For more information about box 3 or other taxation in the Netherlands, contact our colleague Maarten Tervoort in The Hague.