Recent Box 3 proposal in the Netherlands: what expat freelancers need to know in 2026

What is the recent Box 3 proposal, and when could it start?

The recent proposal is the Wet werkelijk rendement box 3. The Tweede Kamer approved the bill on 12 February 2026, and the government still targets 1 January 2028 for a new system based on actual return. For 2026, expat freelancers still file under the current bridge rules, not under the proposed 2028 model.

"We willen het huidige stelsel met de forfaits zo snel mogelijk achter ons laten."

Browse the [Knowledge Hub](/knowledge-hub) for more freelancer accounting guides. The proposal was sent to the Tweede Kamer on 19 May 2025. A Ministry of Finance letter dated 6 March 2026 says the cabinet wants to keep the 2028 target but also discuss improvements, because the ideal long-term design for box 3 is still being debated.

The practical point is simple: nothing in the proposal replaces your 2026 filing rules yet. A sole trader or freelancer living in the Netherlands should treat the 2028 model as a likely future change, but should calculate 2026 exposure using today’s box 3 rules, current thresholds, and the actual-return option that already exists.

• 19 May 2025: the government submitted the Wet werkelijk rendement box 3 to the Tweede Kamer.
• 12 February 2026: the Tweede Kamer approved the proposal.
• 6 March 2026: the cabinet said it wants improvements while keeping the 2028 direction alive.
• Target start date: 1 January 2028.
• 2026 tax returns still follow the current bridge regime.

Does Box 3 apply to a freelancer's business assets or only private wealth?

Box 3 normally applies to private wealth, not to assets already taxed elsewhere. For an eenmanszaak, business assets booked as ondernemingsvermogen belong to profit in box 1, while private savings, investments, crypto and a second home normally stay in box 3. The classification decides whether the €59,357 per-person box 3 allowance matters at all.

The Belastingdienst states that ondernemingsvermogen is not reported in box 3. That means business cash, receivables and assets on the business balance sheet are usually dealt with through business profit. Private assets outside the business remain relevant for box 3 on 1 January, especially when personal savings or investments exceed the tax-free threshold.

Asset labelling still matters for mixed-use items. The Belastingdienst says an asset used 90% or more for business is mandatory business property, while 10% or less business use makes it mandatory private property. A wrong label can distort both profit tax and box 3 reporting, so year-end bookkeeping should match the real use of the asset.

• Business bank balances that remain ondernemingsvermogen usually sit in box 1, not box 3.
• Trade debtors, inventory and tools used in the business normally belong to business profit.
• Private savings accounts, ETFs, listed shares, crypto and a second home usually belong to box 3.
• Your main home is not box 3 if it falls under the Dutch own-home rules in box 1.
• Mixed-use assets need consistent asset labelling before you file.

Which Box 3 rules apply in 2026 while the proposal is not in force?

For 2026, the current box 3 bridge system still applies. The tax-free allowance is €59,357 per person, or €118,714 with a fiscal partner. The box 3 tax rate is 36%, and the provisional 2026 notional returns are 1.28% for bank deposits, 6.00% for investments and other assets, and 2.70% for deductible debts.

These 2026 figures are the numbers that matter for current planning, not the proposed 2028 rules. The bridge system still uses the real mix of assets you hold on 1 January, split between bank deposits, other assets and debts. That makes year-end positioning of private cash, investments and debts more important than broad headlines about future reform.

From tax year 2025 onward, taxpayers can also provide their actual return in the income tax return. The Belastingdienst says it will use the more favourable amount for the taxpayer: the notional return or the actual return. That comparison matters most for people with low interest income, falling crypto or equity values, or high deductible box 3 debt interest.

How does the 30% ruling change Box 3 for some expats in 2026?

Most independent freelancers cannot rely on the 30% ruling for box 3 planning, because the expatregeling requires employment. But expats who already used the 30% ruling before 2024 can still use transition rules through 2026. In that case, the Belastingdienst treats them as non-resident for box 3 and asks only for certain Dutch assets in the return.

The Belastingdienst says new choices for partiële buitenlandse belastingplicht stopped from 1 January 2025. The transition only remains for people who already used the expatregeling before 2024. For those taxpayers, the benefit can still run through the 2026 return, which makes 2026 the final relevant year for many grandfathered expats.

A sole trader without an employer usually does not meet the entry condition, because the expatregeling is tied to working in employment. That is why many expat freelancers with an eenmanszaak have ordinary box 3 exposure on their private assets. If your work is structured differently, the safest check is whether you had a valid 30% ruling and transition rights before 2024.

• From 1 January 2025, new choices for partial non-resident taxpayer status stopped.
• Transition relief can still apply through the 2026 return for qualifying expats.
• The 30% ruling requires employment, not pure self-employment.
• A fiscal partner can only use the partial non-resident option if that partner also qualifies.
• Many expat freelancers with an eenmanszaak therefore have normal box 3 exposure on private assets.

What would change for private savings and investments under the proposed 2028 system?

Under the proposal, box 3 would move from fixed assumed returns to tax on actual return. Interest, dividend, rent and similar direct income would count, and most value changes would also count each year. Real estate and shares in startups would be the main exceptions, because their value gains would generally be taxed when sold instead of annually.

"Je wordt als belastingplichtige straks belast op wat je daadwerkelijk verdient met je vermogen in box 3, waarmee het stelsel rechtvaardiger wordt."

The government says actual return includes both direct return and indirect return. Direct return means items such as interest, dividend and rent, with deductible costs in the proposed new system. Indirect return means positive or negative value changes. Losses could be carried forward against future box 3 income, which is broader relief than the current actual-return counterevidence system gives.

For around 2.5 million taxpayers, the government expects the return to be largely prefilled with data from Dutch financial institutions. The burden will be higher for people with foreign assets, private real estate, non-listed holdings or more complex records. For expat freelancers, that means the record-keeping standard for private investments is likely to rise well before 2028.

• Interest, dividend and rent would count as actual direct return.
• Most annual gains and losses would count as actual indirect return.
• Real estate and startup shares would generally move to tax on sale.
• Losses could offset future box 3 income.
• Your main home would remain in box 1.
• About 2.5 million taxpayers could receive largely prefilled data.

What should expat freelancers do now to avoid surprises?

The best move in 2026 is not to wait for 2028. Review which assets are private and which remain on the business balance sheet, check whether the actual-return option lowers your 2025 tax bill, and confirm whether any expat transition rule still applies. Better records now reduce errors under both the current bridge rules and any future actual-return system.

If you are filing the 2025 return, compare the notional outcome with the actual-return outcome before you submit. Keep bank statements, broker statements, dividend records, debt interest data and valuation evidence for crypto or a second home. For related topics, read the [VAT returns guide for expat freelancers](/knowledge-hub/vat-returns-netherlands-expat-freelancer-guide) and the [deductible expenses guide for freelancers in the Netherlands](/knowledge-hub/deductible-expenses-freelancers-netherlands).

Freelancers who moved cash or assets between business and private accounts near 1 January should document the transfer date and the balance-sheet treatment. Expats who ever used the 30% ruling should check whether transition relief still applies for 2026. That review can prevent a wrong box allocation, a missed actual-return claim or an avoidable mismatch with the tax return.