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 Â The new regime seeks to tax actual returns on investments, moving away from deemed income. Â This shift is intended by the government to create a fairer taxation system, but it would introduce complexities that require careful navigation.Â
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 Â
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 Tax
The 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. Â Exchange results on bank balances in currencies other than EUR will also be taxed. Â
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.
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General Assessment of and Next Steps for the Legislation
Questions 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). Â The House of Representatives can approve, reject, or propose amendments to the bill. Â If it is approved by the House of Representatives, it is sent to the Senate (Eerste Kamer) for approval. Â The Senate can approve or reject the bill.
Looking Ahead: Consequences for Expatriates in the Netherlands
Expatriates 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 Employees
The 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), "." 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. Â
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: “� (20 March 2025).
2 For analysis of the debate around the 30% ruling and the partial non-resident regime, see the following article â€�Dutch Government-Authorised Report on Expatriate Tax Regime Raises Questions about Fate of the 30% Rulingâ€� in Mobility Matters, a ÀÖÓ㣨Leyu£©ÌåÓý¹ÙÍø 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 ÀÖÓ㣨Leyu£©ÌåÓý¹ÙÍø publication,â€�.â€�
Also see (in English), Government of the Netherlands,""
RELATED RESOURCE:
This article is excerpted, with permission, from "" (11 April 2025), a publication of the ÀÖÓ㣨Leyu£©ÌåÓý¹ÙÍø International member firm in the Netherlands.
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