Dutch Investors Have Until 2028. Here Is What to Do Before the Netherlands Taxes Your Unrealised Gains.

If you hold a significant investment portfolio and you are currently tax resident in the Netherlands, you have until January 2028 to decide what to do about it.

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That is not hyperbole. On 13 February 2026, the Dutch House of Representatives passed legislation that will tax Dutch residents at 36% on the annual increase in value of their stocks, bonds, and cryptocurrencies, whether they have sold anything or not. The bill still requires Senate approval, but with the Dutch treasury losing an estimated 2.3 billion euros per year under the previous system, the political direction is clear.

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For internationally mobile investors, the question is not really about the mechanics of the new law. It is about whether the Netherlands is still the right place to be.

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What Is Actually Changing

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The Netherlands taxes investment income under what it calls Box 3. The previous system was struck down by the Dutch Supreme Court in 2021 for being unconstitutional. It taxed assumed returns rather than real ones, meaning savers were paying tax on income they never earned. The replacement, effective 2028, taxes actual returns at a flat 36% rate.

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The problem is how it defines actual returns. The new law includes the annual increase in the market value of assets, even where nothing has been sold. A portfolio that rises by 50,000 euros in a year generates an 18,000 euro tax bill, regardless of whether the investor received a single euro in cash. The only relief is a 1,800 euro tax-free threshold and an unlimited loss carry-forward provision.

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Real estate and qualifying startup shares are handled differently. Tax on those is charged only when the asset is sold. But for liquid investment portfolios, the annual mark-to-market approach applies in full.

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The Practical Problem for Investors

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The most immediate issue is liquidity. Investors with concentrated positions in stocks or crypto may face substantial year-end tax bills without having generated any cash income. They would need to sell assets to fund the liability, potentially at an inopportune time, or fund the tax from other sources.

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For crypto holders this is particularly acute. Dutch crypto holdings have grown significantly in recent years. Unlike equities, crypto portfolios can be highly volatile. An asset that rises sharply in one year and falls the next could generate a large tax bill in year one, with only a carry-forward to offset it in year two. The timing mismatch between taxable gains and actual liquidity is a real structural problem.

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The government acknowledged this directly. It was the stated reason real estate and startups were carved out of the annual valuation approach. But for the majority of investment assets, the problem remains.

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How the Netherlands Compares to Where HPT Clients Actually Go

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Most European countries tax capital gains only when an asset is sold. Germany applies a flat 25% rate at the point of disposal. Norway taxes gains at realisation. France, Spain, and Italy all follow the same basic principle. You pay when you sell.

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The Netherlands from 2028 will be doing something fundamentally different: assessing your portfolio every year and taxing the change in value whether you sold anything or not. Combined with a top personal income tax rate of 49.50%, the overall burden for a high-net-worth investor with a substantial portfolio is significant.

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By contrast, the jurisdictions HPT works with most often for residency planning operate on entirely different principles. The UAE has no personal income tax. Panama and Paraguay operate territorial systems, meaning foreign investment income is not taxed at all. Within Europe, Malta's remittance-based regime and Portugal's NHR successor programme offer meaningful alternatives for investors who are willing to make a genuine move.

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What to Do Before 2028

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The window between now and January 2028 is not as wide as it looks. Establishing genuine tax residency elsewhere takes time. Most jurisdictions require a real change of life: a physical presence, a genuine home, documented ties. A nominal address change will not hold up under scrutiny, particularly for someone leaving a high-tax jurisdiction with a large portfolio.

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The process typically involves selecting the right destination jurisdiction based on your asset profile, income sources, and lifestyle requirements; understanding the exit tax implications of leaving the Netherlands; establishing the new residency in a way that is properly documented and defensible; and restructuring any investment holdings where relevant.

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For investors with crypto-heavy portfolios, the urgency is higher. The combination of unrealised gains taxation and the volatility of digital assets makes the Netherlands a particularly difficult jurisdiction to remain in under the new rules.

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If you are currently resident in the Netherlands and hold a significant investment portfolio, the time to model the exposure and review the options is now, not in 2027.

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Disclaimer: This article is for informational purposes only and does not constitute legal or tax advice. Tax rules change frequently and individual circumstances vary. Consult a qualified adviser before making any decisions based on the information above. Rules and thresholds referenced are current as of February 2026 and the Box 3 legislation is still subject to Senate approval.

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(c) 2026 HPT Group. All rights reserved.

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