The Dutch government has proposed an overhaul under which, as a rule, Box 3 (BOX 3) income will be switched to a realized-gains taxation system at a 36% rate from 2028, and directly held cryptocurrencies will be incorporated into the same framework from 2030. This plan is a key pillar of the comprehensive Box 3 tax reform led by Prime Minister Rob Jetten.
Key points
From 2028, most financial products such as stocks and bonds will be taxed on ‘realized gains’ rather than valuation gains.
Directly held cryptocurrencies and remaining Box 3 assets will move to the same realized-gains taxation system from 2030.
Eyton’s coalition has no parliamentary majority, so support from the opposition is essential for the reform to pass.
Eyton tax reform proposal
As public backlash grew against the government’s previous plan to tax annual increases in asset value even when gains were unrealized, the administration officially decided to change course through a letter sent to Parliament on September 29. The government said it would keep the overarching principle of “taxing actual income,” but described it as an adjustment to reduce concerns about worsening investment conditions.
Under the proposal, stocks, bonds, and other financial products will, starting in 2028, be taxed not when valuation gains arise on the books as a principle, but when income is actually realized—such as through sale. The Dutch Ministry of Finance estimates this would reduce tax revenue by about €15 billion by 2035.
To offset part of this shortfall in tax revenue, the government plans to cut the box 3 tax-exempt income threshold scheduled to be introduced in 2028 from the current €1,800 to €1,000. Eyton Prime Minister said the measure reflects criticism raised in both the upper and lower houses, emphasizing that it is “aimed at strengthening the Dutch investment climate.”
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PwC’s impact of the proposed tax changes
Tax experts at PwC and Forvis Mazars analyze that if the 2028 overhaul goes ahead, roughly 90% of box 3 assets exposed to price fluctuations would effectively be brought into a capital gains tax framework. From an investor’s perspective, the actual timing of tax payments will differ depending on the types of assets they hold, directly affecting portfolio construction strategies.
However, cryptocurrencies held directly do not receive the same treatment immediately. Under the proposal as it stands, crypto and some other assets would still be subject to tax on annual valuation gains during 2028–2029, then shift to taxation on realized gains starting in 2030.
This plan has not yet been enacted into law. Because the three-party coalition led by Prime Minister Eyton lacks a majority in Parliament, opposition support is essential to get the reform passed in both the upper and lower houses.
This debate is part of a continuing trend in the evolution of the Dutch investment tax system—one marked by repeated legal challenges and institutional changes. On December 24, 2021, the Dutch Supreme Court ruled that the existing box 3 system violated European human rights standards because it could tax “income that taxpayers did not actually earn.” After this ruling, the government rolled out a series of corrective measures and has been pursuing a major redesign like the one currently underway.
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