The Dutch system for taxing private wealth is changing more in this decade than in the previous twenty years. Court rulings, political pressure and economic reality have forced a transition from assumed income toward taxation based on actual performance.
For entrepreneurs, directors-major shareholders and active investors, this is not just a tax update. It directly influences how portfolios are structured, how pension capital is accumulated, and whether investments should remain private or move to a holding company.
This guide explains the current regime, the counter-evidence option, what the 2028 system will look like, and how to think strategically about your next steps.
Box 3 explained quickly
Box 3 is the Dutch income tax on privately held wealth. Until 2028, assets are taxed using fictitious return percentages. The resulting income is taxed at 36%.
If your actual return is lower, you may use the counter-evidence rule to reduce the tax burden.
From 2028, the system is scheduled to tax real income and annual value increases.
Why the system changed
For years taxpayers argued that paying tax on assumed returns was unfair when markets performed poorly.
The Supreme Court agreed. The government therefore introduced temporary repair mechanisms and started working on a future model based on actual economic reality.
The transitional regime for 2025 and 2026
Wealth is divided into three categories. Each receives its own notional yield.
| Category | 2025 | 2026 |
|---|---|---|
| Bank deposits | 1.44% | 1.28% |
| Other investments | 5.88% | 6.00% |
| Debts | 2.62% | 2.70% |
The calculated income is taxed at 36%.
Tax free allowance
€57,684 in 2025. €59,357 in 2026. Doubled for partners.
Actual return rule
If your true performance is lower, you may pay tax on the actual amount instead of the fictitious one.
Included in actual return
- Interest
- Dividends
- Rental income
- Unrealised gains
Example calculation (2026)
Portfolio:
- €300,000 savings
- €700,000 shares
Fictitious income:
- €3,840
- €42,000
Total = €45,840 → tax €16,502.
The hidden issue: liquidity versus paper profit
Tax may arise without cash being available. Investors might need to sell assets.
2028 system overview
Real income and real appreciation will form the tax base. For many financial assets this means annual taxation, even without sale.
Why this matters more for DGA’s
DGA portfolios are often larger. They also serve as retirement capital. Compounding is therefore critical.
Private versus holding BV
Inside a holding, returns accumulate before personal taxation. Distribution can be planned.
Benefit 1: compounding on a larger base
When tax is postponed, more capital remains invested.
Benefit 2: timing control
Dividend moments can be aligned with lifestyle.
Benefit 3: reinvestment flexibility
Funds can move between opportunities without entering private taxation.
20 year illustration
€1,000,000 at 6%. Differences grow exponentially.
Exit scenario
Sale proceeds inside the holding allow structured redeployment.
Pension phase
Gradual dividend releases can mimic salary.
Who might lose in the new system
- High growth investors
- Long horizon savers
- People without liquidity planning
Who might benefit
- Low yield savers using counter-evidence
- Investors in real estate with realisation taxation
Preparation roadmap
- Map assets
- Model tax
- Compare structures
- Design dividend path
Why administration quality becomes critical
Proof of actual performance requires accurate records.
Read more about reliable processes in reliable monthly closings.
How Oakhill supports you
We translate legislation into financial strategy.
FAQ
Will unrealised gains be taxed?
Yes, for most financial assets after 2028.
Is BV investing always better?
No, individual factors matter.