Dutch cabinet proposes taxing share and bond gains only when realised

The Dutch cabinet proposes that gains on shares, bonds and options held as private investments be taxed from 2028 only when they are realised, for example on sale, rather than as their value rises each year. A letter to the House of Representatives of 29 September says an amending bill will be tabled and must pass the Senate before 31 December. A smaller allowance, a higher deemed return on other assets and two box 2 measures would fund it.

What the cabinet proposes

Box 3 is the part of Dutch income tax that covers savings and investments. A bill to tax the actual return on those assets from 1 January 2028, the Wet werkelijk rendement box 3, would tax income such as interest, dividends and rent each year, and would also tax each year’s increase in value of assets such as shares, whether or not they are sold. The government’s page on the bill, read on 2 October and not yet updated for the letter, calls that an accrual tax. It says the bill as it stands would tax real estate, such as a second home or a let property, and shares in start-ups and scale-ups only when a gain or loss is realised, and that the House has passed the bill while the Senate has still to deal with it.

The letter, signed by Prime Minister Rob Jetten, Finance Minister Eelco Heinen and State Secretary for Finance E. Eerenberg, proposes to change that. The cabinet will table an amending bill, known as a novelle, extending the capital gains tax to all financial instruments, including shares, bonds and options, from 2028. As a result, the letter says, about 90% of box 3 assets whose value changes would fall under a capital gains tax. The remaining assets would move to a full capital gains tax in 2030; the letter does not list them.

The cabinet calls the novelle the fastest route to bring as much of box 3 as possible under a capital gains tax. It says the change answers criticism of the accrual system in both chambers, gives citizens clarity on how wealth is taxed and strengthens the investment climate.

What pays for it

The letter lists measures in box 3 and in box 2, the box that taxes income from a substantial shareholding in a company:

• The box 3 tax-free allowance would return to its 2020 level, €30,846, from 2027. The Tax Administration puts the 2026 allowance at €59,357 per person, so the cut is almost half.
• From 2028 a tax-free result of €1,000 would apply. On the letter’s own example, a saver earning 2% pays no tax on the first €50,000.
• The deemed return on “other assets”, which the letter says includes rental income and benefits from own use of real estate, would rise by 1.5 percentage points in 2027. In the Tax Administration’s 2026 categories, the matching class covers, among other things, shares, bonds, cryptocurrency, second homes and let property, at a deemed return of 6.00%. The 2027 base percentage to which the 1.5 points would be added is not in the sources read for this article.
• In box 2, the rate of the second bracket would fall by 1.8 points to 29.2% from 2027, for four years. The letter counts this among the funding measures; it says the lower rate encourages owners to take locked-up capital out of their companies.
• The room to borrow “excessively” from one’s own company would be reduced from its current ceiling to €100,000 in five steps of €80,000, starting in 2027. Loans for one’s own home are excluded.

The rate the letter does not set

The letter states no tax rate for the new system. The box 3 rate in 2026 is 36%, according to the Tax Administration. One report, in The National on 1 October, gave 36% as the rate of the new levy; the letter does not say so, and this article did not check what rate the underlying bill sets.

A short timetable

The letter says the Senate must adopt the novelle before 31 December, which makes the timetable ambitious. The cabinet intends to ask the Council of State for urgent advice and asks the House to take the novelle together with the plenary debate on the tax plan. The letter also warns that for at least the first year, banks will not be able to supply the data used to pre-fill tax returns.

For Vietnamese investors

Two groups are within reach of the proposal.

A Vietnamese investor who becomes resident in the Netherlands for tax purposes brings their savings and investments into box 3, including accounts held abroad: the Tax Administration’s 2026 guidance counts bank and savings balances outside the Netherlands. Under the proposal, gains on shares and bonds in such a portfolio would be taxed only when realised from 2028, while interest and dividends would still be taxed each year. In 2027, before the new system starts, the deemed return on those holdings would rise by 1.5 points and the allowance would fall by almost half, subject, as for every box 3 taxpayer, to the rule that a lower actual return is taxed instead.

A Vietnamese investor who stays resident in Vietnam but owns property in the Netherlands is taxed in box 3 only on Dutch assets. Article 7.7 of the Income Tax Act 2001 defines them as Dutch real estate, rights relating to it and certain profit shares in a business managed in the Netherlands, and applies the box 3 rules to them, save for the personal deductions. On the face of that article, the 2027 rise in the deemed return would also apply to Dutch property held from abroad. Whether it adds tax in a given case depends on rules this article did not examine, including the rule, following Supreme Court judgments, that the actual return is taxed where it is lower than the deemed one.

TLT has covered the link between tax and residence and Hungary’s planned wealth tax earlier.

What this article does not establish

The rate that would apply from 2028, which assets move in 2030, and whether both chambers adopt the novelle in time are all open. This article did not read the Netherlands–Vietnam tax treaty or the Senate’s own file on the bill, so it does not say how the treaty affects either group or confirm the bill’s status beyond the government’s page.