ABN AMRO warns 2028 Box 3 tax could penalize investors despite no real gains

ABN AMRO wealth experts Tjarko Denekamp and Peter Beets say the Dutch government’s plan to overhaul the Box 3 wealth tax raises legal and practical concerns. The plan, scheduled to take effect in 2028, would tax income from assets such as savings, stocks, and second homes.

Denekamp and Beets warned that the new system risks starting “with a bitter aftertaste,” noting that lawmakers are working under “significant budgetary pressure” to pass legislation. Under the proposal’s hybrid model, which combines asset growth taxation and capital gains taxation, investors could face taxes even if their portfolios merely recover to the original investment level after losses.

“If the effects portfolio in 2028 only recovers to the originally invested amount, tax must be paid on that recovery, even though no economic profit has been realized,” the experts said.

Other challenges include direct taxation triggered by forming or dissolving marital property communities, gifts, or death, which could force asset sales. Proposed real estate additions could also create tax liabilities without actual income, for example, during prolonged vacancies or non-rentable properties.

The experts urged early government clarification through a recovery law to address these issues, which would make the system “start more credibly.”