new box 3 tax deal approved but changes delayed until 2028

new box 3 tax deal approved but changes delayed until 2028

2026-02-12 economie

Den Haag, donderdag, 12 februari 2026.
the dutch parliament has approved a new system for taxing wealth gains. the change moves away from the controversial fictional yield model used since 2017. under the old rule, people paid tax on assumed returns, even if their investments didn’t grow. this often led to paying taxes without actual profit. the new approach shifts toward a real yield system, meant to be fairer. however, full implementation is postponed until at least 2028. until then, the current method stays in place, with a fixed 6% assumed return for 2026. critics warn the delay costs the state billions in lost revenue. experts say the temporary fix keeps complexity high and fails to resolve core fairness issues. the ruling follows legal pressure after courts ruled past methods unlawful. future plans include taxing only realized profits, such as when assets are sold. for now, millions of savers and investors face continued uncertainty about their tax bills.

parliament approves new wealth taxation framework

The Dutch House of Representatives has approved the Wet werkelijk rendement box 3, marking a pivotal shift in how capital income is taxed [1]. The legislation replaces the long-standing fictional yield model with a system based on actual returns, aiming to align taxation more closely with economic reality [2]. Despite widespread criticism over delays, a broad majority supported the bill amid concerns that further postponement would deepen fiscal losses [3]. Legal rulings had already invalidated key aspects of the prior regime, pushing lawmakers toward compromise [4].

transition period maintains outdated system temporarily

Until the new law takes effect in 2028 at the earliest, taxpayers remain subject to the existing box 3-belasting rules based on fictief rendement [5]. For 2026, the assumed rate stands at 6%, down from an initially proposed 7,78% following parliamentary intervention [6]. The projected rate for 2027 is estimated at 6,37% according to tax advisor Cor Overduin [7]. During this interim phase, individuals continue paying taxes on paper gains rather than realized profits, creating mismatches between liability and liquidity [8].

financial impact remains significant for households

Under the current 6% fictief rendement, someone with €100.000 in savings faces a taxable base of €6.000 [9]. Applying the standard tax rate of 36%, this results in a tax obligation of 2160 = €2.160 [9]. By comparison, a projected 6,37% rate in 2027 would raise the burden to 2293.2, amounting to €2.293—highlighting growing pressure on personal finances [7]. These figures underscore why critics argue the transitional arrangement unfairly burdens savers and investors who may lack liquid funds to cover assessments [10].

The overhaul stems directly from judicial decisions, including a landmark 2021 ruling by the Hoge Raad declaring parts of the previous system unlawful [11]. A subsequent emergency measure introduced in 2022 also failed legal scrutiny, leaving the government reliant on stopgap solutions [12]. With each year of delay costing the treasury billions due to missed revenues, urgency mounted within the coalition [13]. However, fundamental disagreements persist over whether taxation should apply to ongerealiseerde winst or await asset realization through sale [14].

industry voices caution over practical shortcomings

Financial institutions like ABN AMRO warn that the hybrid model risks imposing levies even when no economic gain occurs [15]. Their analysts point to scenarios where portfolios recovering from earlier losses could still trigger tax liabilities—a situation described as having a “bittere nasmaak” [15]. Special concern exists around illiquid assets such as real estate, where owners might need to sell property just to settle dues arising from theoretical appreciation [16]. Without preemptive adjustments, experts fear renewed legal challenges and public dissatisfaction [15].

path forward includes evaluation and potential revision

Parliament has mandated that a comprehensive plan for a full vermogenswinstbelasting regime must be presented by Prinsjesdag 2028 [17]. This future model aims to tax only realized profits upon disposal of assets, addressing equity concerns raised across party lines [18]. An amendment passed alongside the current law requires official evaluation of its functioning after three years [19]. As noted by fiscal economist Edwin Heithuis, “het is fijn dat we naar iets beters gaan, het is alleen jammer dat het zo lang heeft moeten duren” [20].

Bronnen


box 3 hervorming spaartaks