On February 12, 2026, the House of Representatives approved the bill Act on Actual Yield Box 3. The intended start date is January 1, 2028. The Senate still needs to approve it, but the outlines of the new system are clear.

The current system of notional returns will disappear. Instead, tax will be imposed on actual realized returns.

Main rule: wealth tax

The starting point will be annual tax on:

• Interest, dividends, and rental income

• Realized and unrealized capital gains

• Minus deductible costs and interest on debts

Important difference: paper profits (for example, stock market increases without sales) count in the relevant tax year.

Losses can be carried forward indefinitely (with a threshold of €500).
The tax-free allowance will be replaced by a tax-free result of €1,800 per person.
The proposed rate is 36%.

Exception: real estate and start-ups

For real estate in box 3 and shares in startup companies, a different system applies: capital gains tax.

Here, capital gains are only taxed upon sale.

However, annual benefits are taxed:

• Actual rental income at ≥90% rental

• Or the higher of actual rent or 3.35% of the WOZ value (real estate addition) at less than 90% rental

For example: a vacation home that is not rented out receives an addition of 3.35% of the WOZ value.

What does this mean in practice?

The shift to actual returns means:

• More focus on liquidity planning

• Annual tax pressure during strong market increases

• Possibility of loss offsetting in negative years

• Differences in treatment between liquid investments and real estate

Furthermore, the choice between private (box 3) or structuring via a BV (box 2) may become more relevant in some situations. Subsequent transfer can be fiscally costly due to transfer tax.

In summary

Starting in 2028, box 3 will shift from a notional model to a system that aligns more closely with actual yield. This increases complexity, but also aligns better with economic reality.

For investors and wealthy individuals, it is wise to gain insight into the possible impact on their situation in a timely manner.

This message is intended solely for information purposes and does not constitute tax or investment advice.