The 2028 reform is not settled, but today’s records and private liquidity already matter.
A founder calls after a good year. The BV has paid its tax, the VAT is clean, the salary has been booked, and there is still private money on the side: savings, an investment account, perhaps a second home, perhaps a loan to a family member. His question is not theoretical. He wants to know whether Box 3 is finally moving toward something fairer, and whether he still needs cash ready. That makes Dutch Box 3 control a records problem, not only a private tax calculation.
Private wealth now needs a record
That is the real shape of this file. Box 3 is no longer just a tax topic. For small business owners, it sits next to payroll timing, private bills, and the money that keeps a household steady when business cash is late.
The bridge is not finished
I read Box 3 as a bridge between two systems. On one side sits the current route, where the Belastingdienst still works with fictitious returns unless actual return is lower under the counterproof regime. On the other side sits the proposed 2028 system, where direct return and value changes become the main tax base.
Rijksoverheid still points to a new Box 3 system from 1 January 2028. Overheid.nl shows the Wet werkelijk rendement box 3, Kamerstuk 36748, now in Eerste Kamer treatment after Tweede Kamer adoption on 12 February 2026. A Ministry of Finance letter from 6 March 2026 says the law is meant to make actual-return taxation possible from 2028, while work continues toward a fuller capital-gains system after that.
That is the message owners should hear. The direction is set, but the present years still have to be paid, proved and sometimes corrected.
Today’s calculation still bites
For the 2026 provisional assessment, the Belastingdienst uses a Box 3 tax-free amount of €59,357 without a fiscal partner and €118,714 with a fiscal partner. The provisional return percentages are 1.28 percent for bank balances, savings and cash, 6.00 percent for other assets, and 2.70 percent for debts. The tax on the calculated Box 3 return is 36 percent.
Those percentages are provisional, but the cash effect is not. A small entrepreneur can be reading about 2028 while paying a 2026 assessment based on today’s forfaits. Where actual return is lower, the Opgaaf werkelijk rendement route may matter. That route asks for work.
Timing is part of the tax story
For each year, a separate actual-return statement is needed. Belastingdienst says taxpayers must collect the data themselves. No attachments go with the form, yet the evidence still has to exist if questions come later. The 2026 annual plan also shows heavy capacity pressure around this work, with an estimate that up to 975 FTE could be needed.
Actual return is wider than cash
Many owners hear actual return and think only of cash received. Interest. Dividend. Rent. That is only part of the picture. Under the current counterproof route, actual return includes real income from assets and value changes during one calendar year.
The tax-free amount does not apply to that actual return. Negative total actual return for a year is set at zero. Costs are generally not deductible in the current recovery route, with limited exceptions such as interest on Box 3 debt. The Hoge Raad set that legal floor in ECLI:NL:HR:2024:704. If fictitious taxation exceeds actual return, the assessment must be reduced within that recovery framework.
The proposed 2028 system has another logic. It allows cost deduction and loss treatment in ways the current route does not. It also gives real estate and certain startup and scale-up shares capital-gains treatment on realisation rather than annual accrual.
These systems should stay separate in any kitchen-table calculation.
The private ledger meets the company
Back to the founder with the BV. His company ledger may be tidy. His private Box 3 position may not be. The investment platform has statements. The second home has a value and perhaps rent. The private loan may have a contract, or only a bank transfer and family memory. The dividend decision sits between company cash and household liquidity.
That is where Box 3 becomes practical. It is formally about private wealth. In real life, it sits next to business survival. The same household cash may cover VAT timing, payroll gaps, private tax, mortgage payments and a slow customer month.
DNB’s Q1 2026 figures show why the debate stays sensitive. Dutch households held €207.6 billion in securities, €540.6 billion in savings accounts at Dutch banks and €107.2 billion in payment accounts. CBS provisional 2024 figures put total private-household assets at €3,769.7 billion and total wealth at €2,754.4 billion.
What founders should separate
Those are macro numbers, not one owner’s tax bill. Still, they explain the pressure behind the reform. The Netherlands is not adjusting a small technical corner. It is changing how private wealth is read, timed and evidenced.
Keep the files apart
The response is not drama. It is separation.
Separate current counterproof from 2028 planning. Separate cash received from value movement. Separate company money from private liquidity. Separate partner allocation choices from later relief hopes. Separate what is already law from what is still a proposal.
A tax adviser will still need to handle the technical position. The owner can already improve the file. A year-by-year overview of assets and debts is a clean start. So is a trail for interest, dividends, rent, debt interest, valuations and private real estate use. For founder holdings, share registers, option records, valuation support and qualification documents matter.
None of this needs panic. It needs timing discipline. A possible later correction does not pay a bill due today. A proposed future deduction does not help under current counterproof. A value increase may look good on paper and still create a cash question.
Box 3 will keep moving. The better discipline is quieter: know the assets, know the years, know the documents, and keep enough cash sense around the tax file to avoid surprises from a system still under construction.
Sources
- Tweede NnavV Wet werkelijk rendement box 3 – Taxence
- Rijksoverheid – Official shape of the proposed 2028 Box 3 system
- Overheid.nl Wetgevingskalender – Current legislative status
- Rijksoverheid, Ministry of Finance – Government update on improvements, 2028 start and later capital-gains development
- Belastingdienst – Current 2026 provisional Box 3 calculation
- Belastingdienst – Counterproof and actual return before the new law
- Belastingdienst – Opgaaf werkelijk rendement process
- Belastingdienst Newsroom – Belastingdienst capacity pressure
Referenced in the article
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The Polder is written for readers who need the Dutch business environment translated into practical meaning. Corrections, source policy and editorial accountability are part of the publication record.
