A changing landscape for investors
For successful investors, the upcoming Box 3 system (effective from 2028) is not good news. The days of the so-called “fun box” are over.
The current system of taxation on deemed returns may feel unfair to many – and has even been ruled unlawful by the Supreme Court – but it has certainly benefited those achieving returns above the fixed deemed rate. In 2025, that deemed return is set at max 5.88%. Cryptocurrencies, tech stocks, and real estate have in recent years often easily outperformed that figure.
Example
Suppose you held €100,000 in Ethereum on January 1, and by December 31 it was worth €130,000.
- Under the current system: you would pay 36% tax on a deemed return of €100,000 × 5.88% = €2,117.
- Under the new system: you would pay €10,800, i.e. 36% of the actual gain (€130,000 – €100,000).
The same applies to real estate. From 2028, anyone selling property, will pay 36% tax on the gain since the reference date (January 1, 2028).
For instance, an apartment worth €500,000 that appreciates by 5% per year creates a latent tax liability of more than €9,000 annually. And that comes on top of the 36% tax already levied on rental income
A note on politics
(For the politically inclined: this is the result of 15 years of VVD leadership in government.)
Looking for solutions
While the new system does bring some advantages – no tax in years with losses, and the possibility of offsetting losses – many wealthy people will look for alternatives.
Some “tricks” have already been suggested, such as artificially reducing returns within a given period. However, we expect these loopholes to be closed before the system takes effect. Structural solutions will therefore be necessary. Two main strategies stand out:
- Exit Box 3.
- Exit the Netherlands.
Strategy 1: Exit Box 3
Box 3 only taxes private investment income and so-called “separated private assets.” Assets held in a BV (private limited company) do not fall under Box 3.
This makes a BV an attractive strategy for tax deferral. The corporate tax rate on the first €200,000 of profit is just 19%, and for assets such as real estate or cryptocurrencies, only realized gains are taxable.
That aligns with the new Box 3 treatment for real estate – but not for crypto. In other words: whether a BV is useful depends largely on the type of investments you make. Always seek advice in advance.
Drawbacks: Dividends distributed from a BV to its owner are taxed at 24.5–31%. This makes the ultimate tax burden higher. However:
- There is no obligation to distribute dividends, and an owner may borrow up to €500,000 from their BV without triggering dividend taxation.
- The (arm’s-length) interest on this loan is taxable in the BV but deductible in Box 3 at a higher rate under the new system.
- The initial capital contribution can, under certain conditions, be withdrawn tax-free as a return of capital, further enabling tax deferral.
Strategy 2: Exit the Netherlands
An increasingly popular approach is emigration. The growing regulatory and tax burden is becoming too heavy for many entrepreneurs and investors.
There are numerous countries without wealth tax – or even without income tax altogether. Popular destinations include Dubai (UAE), where I frequently advise clients, as well as Singapore, Portugal, Andorra, Qatar, Montenegro, and Bulgaria.
Important: Always seek professional advice before emigrating. The Netherlands applies various exit taxes, which can often be significantly reduced or deferred with timely planning.
Note: Dutch real estate remains taxable in the Netherlands, regardless of residence. Conversely, international tax planning may create advantages: investments in real estate located in countries with favorable tax treaties – particularly where that country itself imposes little or no tax – can provide a net benefit in the Netherlands. Dubai is a prime example, but other options exist.
