Box 3 and the Switch to Actual Returns: Plan Your Investment Mix

The system as it is now

Above the allowance of €59,357 per person, the tax in box 3 is based on an assumed return for each type of asset. The assumed return is low for savings and much higher for investments. Fiscal partners have a double allowance. The assumed return is taxed at 36%. If your real return was lower than the assumed return, you can use the counter-evidence procedure. The courts forced this procedure through. You document the real result and claim the lower base.

The switch to actual returns

Under the announced system, you pay tax on what your investments really earn. Under the current drafts, both realised and unrealised gains count. Until then, the transitional rules now in force apply. The important decision is therefore where you keep each asset. For savings, the result is about the same in both systems. For growth assets, choose carefully where you keep them.

A holding structure has two Dutch companies, one above the other. Each company has its own deed of incorporation. See the Dutch holding structure for non-residents. For the shareholder register, the board decisions and the yearly filings of both companies, see corporate secretarial services in the Netherlands.

The notary, the Tax Administration and the bank all ask for the company address first. You choose that address and sign the contract yourself. See what the law asks of a business address in the Netherlands.

The box-2 alternative

Wealth inside a BV falls entirely outside box 3. The company pays 19% tax on profit up to €200,000. Distributions are taxed in box 2 at 24.5% on the first €68,843 per person and 31% above that (2026), at a moment you choose yourself. For portfolios above the allowance, this is the usual choice. See the European context and the family-bank pattern. Each January, you review the split. You keep the private part close to the allowance and leave the rest in the company. The owner has two more options. A salary below the standard amount of €58,000 is allowed if comparable work pays less, or for up to three years while a new BV is still too small to pay that amount. A prior consultation with the Tax Administration gives you certainty in advance. You can also borrow up to €500,000 from your own BV. The lower salary is what saves tax. At €36,000 compared with €58,000, you keep about €7,100 a year more. After a later dividend, about €2,800 of that remains. The loan gives you access to money, but the tax stays the same. Calculate it with your own figures. See the combination of salary and borrowing.