The Netherlands is reforming Box 3 (English: wealth tax box) in two phases: first an average increase of 17% in 2027 driven by WOZ (English: property valuation) increases and the forfaitair rendement (English: deemed return), then the Wet werkelijk rendement (English: Act on actual return) in 2028. The changes affect primarily small investors and property owners. The reform follows years of criticism of the forfaitair stelsel (English: deemed-return system). The Hoge Raad (English: Supreme Court) will rule on 25 June 2026 on refunds to non-objectors, while the cabinet announces new options for the legislation. Professors warn that a European exemption for investing could threaten Box 3 revenues.
What changes in Box 3 in 2027 and 2028 For 2027, the Box 3 levy rises an average of 17% on real estate, driven by WOZ increases and the forfaitair rendement. The forfaitair stelsel remains in force for now, with the Belastingdienst (English: Dutch Tax Authority) applying a notional return to wealth above the exemption threshold. From 2028, the Wet werkelijk rendement box 3 takes effect. On Prinsjesdag 2026, a novelle is expected containing further amendments. The act aims to tax actually realised returns rather than the forfaitair rendement, but implementation remains complex. A European tax exemption for investing within the EU could threaten Box 3 revenues, according to professors. The exemption could encourage tax avoidance and undermine the effectiveness of the reform.
Impact on small investors and property owners Small investors are hit hardest by the reform, particularly from 2028 onward. The werkelijk-rendementstelsel (English: actual-return system) brings higher administrative burdens and complexity. Property owners see their tax rise due to WOZ increases, regardless of actual return. The 17% increase in 2027 affects primarily those who own real estate with a WOZ value above the exemption threshold. The forfaitair rendement remains in force in 2027, meaning tax is owed even when the actual return is negative. The Hoge Raad will rule on 25 June 2026 on refunds to taxpayers who did not file an objection against earlier assessments. This ruling could have financial consequences for thousands of households.
The Netherlands
as a destination: what the numbers show The Netherlands levies an effective 24% tax on income, compared with 0% in Dubai (AE) or Monaco (MC). On an average Dutch gross income of EUR 54,000, relocation to Dubai yields an indicative net saving of EUR 12,878 per year, according to Libaros calculations. Box 3 adds an additional layer: wealth above the exemption threshold is taxed at a forfaitair rendement, regardless of actual return. The shift to the werkelijk-rendementstelsel in 2028 partially addresses this, but introduces new complexity. For those combining wealth and real estate, the total tax burden rises. WOZ increases and the forfaitair rendement in 2027, followed by administrative burdens in 2028, make the Netherlands less attractive for wealth accumulation. Dubai, Andorra (AD) and Bulgaria (BG) levy 0% wealth tax. The reform illustrates the tension between fairness and workability. Whether the werkelijk-rendementstelsel delivers the promised improvement depends on implementation and the European context. For those with mobility, the calculation shifts toward destinations without wealth taxation.