Netherlands to start taxing unrealized capital gains yearly from 2028
Recorded: Dec. 2, 2025, 3:04 a.m.
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Netherlands – New Law Introduces Capital Growth Tax and Capital Gains Tax for Box 3 person person close Preferences Profile Logout article Submit RFP Global (EN) expand_more close Search cancel menu close Our Insights Back All Insights AI and Technology ESG Operations Risk and Regulation Transformation Value Creation Workforce What we do Back Industries Consumer, Retail & Leisure Energy, Natural Resources & Chemicals Financial Services Healthcare Government & Public Sector Private Enterprise Services Advisory AI Audit and Assurance ESG Legal Tax Global Alliances & Ecosystems Microsoft Oracle Salesforce SAP ServiceNow Workday About KPMG Careers Back KPMG Careers Who we are What we do Working at KPMG Job search person person close Preferences Profile Logout article Submit RFP Global (EN) expand_more person person close Preferences Profile Logout search Search search Your search term was too short. Previous search terms close Cancel Home Our Insights GMS Flash Alerts Netherlands – New Law Introduces Capital Growth Tax and Capital Gains Tax for Box 3 Netherlands – New Law Introduces Capital Growth Tax and Capital Gains Tax for Box 3 GMS Flash Alert 2025-116 | 13 June 2025 Share On 19 May 2025, the Dutch Deputy Minister of Finance presented a new bill to the Dutch Parliament aimed at reforming the taxation system for income derived from assets, known as the ‘Actual Return on Investment in Box 3 Act’ (Wet werkelijk rendement box 3). Scheduled for implementation on 1 January 2028, this bill proposes significant changes to the current regime, affecting both taxpayers and the Dutch Tax and Customs Administration (Belastingdienst).1 WHY THIS MATTERS This legislative change may be crucial for taxpayers, including expatriates, considering the end of the partial non-resident regime.2 The new regime seeks to tax actual returns on investments, moving away from deemed income. This shift is intended by the government to create a fairer taxation system, but it would introduce complexities that require careful navigation. The impact is expected to be far-reaching, influencing tax liabilities and administrative processes.The proposed changes would impact the global-mobility programme costs for employers with a tax-equalisation policy (partly) covering income from savings and investments. Dutch Personal Income Tax Regime The Dutch personal income tax regime3 is divided into three separate boxes:Box 1 covers business and employment income and income from home-ownership of a main private residence;Box 2 covers income and gains from substantial shareholdings;Box 3 covers income from savings and investments.All boxes have their own applicable tax rates.Box 3: Changing to a Capital Growth Tax and Capital Gains TaxThe bill regarding Box 3 introduces two main categories of taxation: capital growth tax and capital gains tax. The capital growth tax will apply to most assets, taxing both realised and unrealised returns, including appreciation in value and income from assets like shares, cryptocurrencies, and savings. Exchange results on bank balances in currencies other than EUR will also be taxed. The capital gains tax will focus on immovable property and certain start-up investments. All ‘annual’ benefits, such as dividends and rental income, will also be taxed, and costs, such as interest on loans and maintenance costs will be deductible. In addition, positive appreciation in value will be taxed and depreciation in value will be deductible. But unlike the capital growth tax, capital gains tax will, in principle, only be levied at the time of realisation. This is usually when the relevant asset is sold, but also when immovable property exits Box 3 for another reason, such as emigration. KPMG MEIJBURG & CO INSIGHTS General Assessment of and Next Steps for the LegislationQuestions remain around the taxation of savings and investment income. It remains highly uncertain whether this legislation will swiftly resolve all issues related to the taxation of income from assets. The proposed capital growth tax diverges from international norms which makes it even more important to assess on a case-by-case basis what the impact is of a taxpayer’s migration to another country.Before the bill can come into effect, it is reviewed by the House of Representatives (Tweede Kamer). The House of Representatives can approve, reject, or propose amendments to the bill. If it is approved by the House of Representatives, it is sent to the Senate (Eerste Kamer) for approval. The Senate can approve or reject the bill.Looking Ahead: Consequences for Expatriates in the NetherlandsExpatriates residing in the Netherlands who qualify as Dutch tax residents are generally required to pay taxes on their worldwide income in the Netherlands. Previously, the partial non-resident regime allowed individuals with the 30% ruling (‘expat ruling’) to be largely exempt from Box 2 and Box 3 taxes, with certain exceptions. With the elimination of the partial non-resident regime (per 1 January 2025, and per 1 January 2027, for those entitled to transitional law), all individuals under the 30% ruling will lose their near-total exemption from taxes on substantial shareholdings (Box 2) and savings and investments (Box 3). They will be taxed in the Netherlands on their worldwide income, provided they are considered Dutch tax residents, and the above-mentioned changes to Box 3 will apply to them as well.Considerations for Employers, Including Those with Globally Mobile EmployeesThe proposed changes are expected to impact global-mobility programme costs for employers with a tax-equalisation policy (partly) covering income from savings and investments.Employers with questions about this amendment or how it might affect the situation of their (international) workforce, may wish to consult with their qualified cross-border tax professional or with a member of the People Services team with Meijburg & Co. in the Netherlands (see the Contacts section). FOOTNOTES:1 See (in Dutch) on the Dutch government website: Rijksoverheid, Nieuwsbericht (19-05-2025), "Wetsvoorstel werkelijk rendement box 3 aangeboden aan Tweede Kamer." The enforcement is planned to begin as of 2028, but questions have arisen about the impact of the collapse of the cabinet on 10 June 2025, and what’s next for the current caretaker government. Additionally, be aware that this proposal is different from the bill on rebuttal provision actual return on investment Box 3 with respect to the years 2017-2021, which was proposed on 13 March 2025. We refer to our article: “Bill on rebuttal provision actual return on investment Box 3” (20 March 2025).2 For analysis of the debate around the 30% ruling and the partial non-resident regime, see the following article “Dutch Government-Authorised Report on Expatriate Tax Regime Raises Questions about Fate of the 30% Ruling” in Mobility Matters, a KPMG publication. (Readers should bear in mind that developments have progressed since the Mobility Matters article was published.)3 For more background on the taxation of income in the Netherlands, see the KPMG publication,”Taxation of International Executives: Netherlands.”Also see (in English), Government of the Netherlands,"Types of income tax." RELATED RESOURCE:"Final bill on Actual Return on Investment in Box 3 Act published” (21 May 2025), a publication of Meijburg & Co, a member firm of the KPMG global organization of independent member firms. Contacts Ruben Froger Partner and Head of the People Services practice KPMG Meijburg & Co. call Sandy Govers Senior Tax Manager KPMG in the Netherlands More Information Download PDF Download and save the PDF version of this GMS Flash Alert. Download Subscribe to GMS Flash Alert GMS Flash Alert reports on recent global mobility-themed developments from around the world to help you better understand what has changed and what that means for you. Subscribe now GMS Flash Alert Visit GMS Flash Alert home Disclaimer The information contained in this newsletter was submitted by the KPMG International member firm in the Netherlands.GMS Flash Alert is a Global Mobility Services publication of the KPMG LLP Washington National Tax practice. The KPMG name and logo are trademarks used under license by the independent member firms of the KPMG global organization. KPMG International Limited is a private English company limited by guarantee and does not provide services to clients. No member firm has any authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. 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This document details a significant shift in the Dutch tax system, introduced through the ‘Actual Return on Investment in Box 3 Act’ (Wet werkelijk rendement box 3), scheduled for implementation on January 1, 2028. The core of the change revolves around reforming the taxation of income derived from assets, specifically moving away from the previous deemed income approach within Box 3. Currently, the Dutch personal income tax system is divided into three boxes: Box 1, Box 2, and Box 3. Box 1 covers business and employment income, alongside income from home-ownership. Box 2 addresses substantial shareholdings, and Box 3 focuses on savings and investments. The proposed legislation fundamentally alters Box 3, introducing a capital growth tax and a capital gains tax. The most impactful change is the introduction of the capital growth tax, which will apply to most assets, including shares, cryptocurrencies, and savings. This tax aims to capture both realized and unrealized returns, reflecting the assets’ actual performance. Alongside this, a capital gains tax will be levied on immovable property and certain start-up investments. Importantly, the capital growth tax distinguishes itself from the capital gains tax by taxing ‘annual’ benefits, such as dividends and rental income, and allowing for the deduction of costs like interest and maintenance expenses. Unlike the capital gains tax, which is typically triggered upon the sale of an asset, the capital growth tax applies generally. A crucial element of this reform is its impact on expatriates residing in the Netherlands. Previously, the partial non-resident regime – the ‘expat ruling’ – offered significant tax exemptions for individuals with substantial savings and investments under Box 3. However, this regime is being phased out: effective January 1, 2025, and January 1, 2027, those benefitting from the 30% ruling will lose these exemptions. Consequently, they will be subject to taxation on their worldwide income, including income derived from Box 3 assets, unless they qualify for transitional law provisions that remain in effect for a specific period. The proposed changes also affect employers, particularly those with globally mobile employees. The shift towards a capital growth tax increases the cost of implementing a tax equalization policy, which is frequently used to manage the tax implications of international assignments. Careful scrutiny is needed to navigate the complexities of this new system. The legislative process involves review by the House of Representatives (Tweede Kamer) and ultimately the Senate (Eerste Kamer) for approval. The eventual implementation on January 1, 2028, highlights the significant implications of this reform, necessitating a robust assessment of its impact on individual tax liabilities and administrative processes. The document advises careful case-by-case analysis to accurately assess the changes. |