Han Dieperink: Box 3, a missed opportunity of historic proportions

February 17, 2026

_{This column was originally written in Dutch. This is an English translation.}

By Han Dieperink, written in a personal capacity

The House of Representatives has spoken. With ninety votes in favour, the Actual Return Box 3 Act has been passed. From 2028 onwards, Dutch citizens will pay tax on their actual capital gains rather than on a notional percentage. Problem solved, one might think. Nothing could be further from the truth.

What the House has approved is a monstrosity of compromises that satisfies virtually no one. Even before the final votes had been counted, a majority decided that the next cabinet must come up with a new proposal. A law that is already obsolete when it is introduced: that says everything about the quality of what is now on the table.

Paying tax without having any money

The most absurd element of the new system is the capital gains tax. Anyone who invests in shares, bonds or crypto will now pay 36% tax on price increases, even if nothing has been sold. An investor who calmly holds on to their portfolio for the long term may receive a hefty tax bill after a good year on the stock market without having a penny of cash available. The consequence is predictable: forced sales to pay the tax authorities. That is not a capital gains tax, it is capital destruction.

At the same time, capital gains tax does apply to real estate, but this is only paid when the property is sold. The property investor can let his assets grow quietly, while the share investor has to dig into his pocket every year. Anyone who can explain this inequality without resorting to budgetary jargon deserves a medal.

The small investor as victim

In public communications, it sounds reassuring: the first €60,000 remains tax-free. But that only applies to a return of 3%. The new system replaces the capital allowance with a tax-free result of 1,800 euros. However, at a 6% return, only 30,000 euros is effectively exempt, and at 9% only 20,000 euros. Small investors who have a good year pay tax on a much lower amount of capital than savers who leave their money safely in the bank.

The Netherlands is already a country of savers, with almost €400 billion gathering dust without earning any interest. From an economic perspective, this is detrimental: money in savings accounts contributes little to productive investment. The new system reinforces this imbalance by discouraging investment and rewarding saving.

The return of fiction

It gets even more absurd. For unrented homes, the legislator is introducing a flat-rate additional tax liability of 3.35% on the WOZ value. A second home that is vacant or temporarily uninhabitable does not generate rental income, but is taxed as if it did. The Actual Return Act thus introduces precisely the fiction it was supposed to abolish. You couldn't make it up.

In all fairness, it must be said that almost everyone knows what is going on here. The current temporary regime costs the treasury more than two billion euros annually and is legally vulnerable after the Kerstar ruling. The political choice was limited: this flawed proposal or an even more expensive vacuum. Box 3 generates four to five billion euros per year, and the government cannot afford to lose that money. But is that really the case?

The alternative that no one dares to mention

Suppose the Netherlands were to abolish Box 3 entirely. Revolutionary? Certainly. Unfeasible? Not at all.

In recent decades, the Netherlands has seen a steady stream of wealthy citizens leaving for Belgium, Switzerland, Portugal and other more tax-friendly places. Not because they did not love their country, but because wealth tax forced them to choose between loyalty and common sense. Abolishing Box 3 would reverse this trend in one fell swoop.

The Dutch economy is worth roughly one trillion euros. An extra 1% growth from returning Dutch citizens and newly attracted Europeans who see our country as an attractive alternative would quickly generate ten billion euros. On average, 40% of this goes to the treasury via income tax, VAT and other levies. That is four billion euros, exactly the yield from box 3. With 2% extra growth, abolishing it would yield considerably more than maintaining it. And that's not even mentioning the indirect effects: more investment, more employment, more innovation, a more attractive business climate for entrepreneurs and talent.

The bill that is not being calculated

The tragedy is that this calculation is not being made in The Hague. The four to five billion from box 3 is neatly included in the budget. The missed growth due to wealthy Dutch people leaving the country is not. The costs of a complex tax system that forces millions of citizens to file complicated tax returns are not. The social costs of a country that rewards saving and punishes investment are not. Box 3 is not a wealth tax. It is an emigration tax, paid by those who stay.

Conclusion

The House of Representatives had the opportunity to make a fundamental choice. Instead, ninety MPs opted for a half-baked compromise that will have to be revised again in two years' time. A system that taxes paper profits, disadvantages small investors and reintroduces fictions in the property sector. A system that, in the words of the House itself, is only an interim step.

Abolishing box 3 remains the best solution. Not despite the budgetary consequences, but precisely because of the economic potential. A country that welcomes its wealthy citizens instead of driving them away does not need to worry about tax revenue. That will come naturally, through growth rather than taxation. But that requires political courage. And that was not on the agenda.

More columns by Han Dieperink