Emigration as a Box 3 exit
Leave the Netherlands and you stop paying Box 3. But emigration has tax consequences that go beyond the wealth levy. Here is what you need to know.
Box 3 stops after departure
No NL tax residency = no Box 3 levy on investment assets
Popular destinations
UAE (0% income tax), Belgium (no capital gains), Portugal (IFICI), Spain
Note: conserverende aanslag
Box 2 shareholders carry a tax claim when they leave
Why do people consider emigrating?
The upcoming Wet Werkelijk Rendement makes Box 3 more impactful than ever before. Unrealised capital gains will soon be taxed annually at 36%. For investors with significant holdings in equities or ETFs, this can represent a structural drag on compounding returns.
For some investors, emigration has therefore moved beyond a thought experiment. Especially when other reasons are present, such as work abroad, an international lifestyle or a partner in another country, the fiscal component can tip the balance.
Emigration is a major life decision. Fiscal savings are rarely the only reason. This article covers only the tax side. Personal and practical considerations are outside scope.
What changes fiscally when you leave?
Box 3: levy stops after departure
Box 3 is calculated based on your situation on 1 January (the reference date). If you are still a Dutch tax resident on 1 January, you pay the full Box 3 levy for that year, even if you emigrate later that year. The following year you are free from Dutch Box 3, provided you are no longer a tax resident.
Strategically emigrating before 1 January of a tax year can therefore be worthwhile. But note: tax residency is more than a registration. The Dutch Tax Authority looks at your actual living and working situation.
Conserverende aanslag: for Box 2 shareholders
If you hold a substantial interest (5% or more in a BV), the Dutch Tax Authority imposes a conserverende aanslag upon emigration. This is a tax claim on the accrued but not yet realised gain in your BV shares. The assessment is not immediately collected, but remains outstanding.
For emigrations after 15 September 2015, the conserverende aanslag has no fixed end date. The claim only expires once the shares have been sold or dividend paid and the corresponding tax settled. Via tax treaties the actual levy may be limited, but the claim itself remains.
Do you have a BV? Get advice from a tax adviser specialising in emigration before taking any steps.
AOW: accrual stops when you leave
You accrue AOW entitlements for each year you are insured in the Netherlands between the ages of 17 and 67. Each full year of insurance entitles you to 2% of the full AOW benefit. If you emigrate before 67, accrual stops and you have an 'AOW gap': a lower benefit later.
You can voluntarily insure the gap through the SVB (Social Insurance Bank), provided you register within a year of departure. The premium depends on your age and income.
Pension: accrued rights remain, but...
Pension entitlements built up through a Dutch employer are preserved. But based on tax treaties, the Netherlands retains taxing rights in many cases over pension payments that were built up with Dutch fiscal facilitation. This means you may still pay Dutch tax on that pension later, even if you live abroad at the time.
The exact rules depend on the tax treaty with the destination country. For DGA (director-shareholder) pension, additional emigration rules apply that require extensive professional advice.
Popular fiscal destinations
The countries below are most commonly considered by Dutch nationals for fiscal reasons. This is a concise overview of the main points. Details are complex and change regularly, so always verify the current situation.
United Arab Emirates (Dubai)
No income taxAdvantages
- No personal income tax
- No capital gains tax
- No Box 3 equivalent
- Strong ecosystem for entrepreneurs
Considerations
- Corporate tax 9% (above AED 375k profit, since 2023)
- High cost of living
- Large cultural and practical adjustment
- Distance from family/network
Belgium
No capital gains taxAdvantages
- No capital gains tax on private investments (in principle)
- No Box 3 equivalent
- Geographically close to the Netherlands
- Same language (Flanders)
Considerations
- Progressive income tax up to 50%
- Cadastral income on real estate
- Active trading can still be taxed
- Tax authority scrutinises fictitious emigration
Portugal (IFICI)
20% flat rate (IFICI)Advantages
- IFICI regime: 20% flat rate on Portuguese-source active income (10 years)
- Popular among European expats
- Relatively low cost of living
Considerations
- NHR (old regime) abolished as of 1 January 2025, replaced by IFICI
- IFICI is more restrictive than NHR was
- Investment income taxed at 28%
- Capital gains on shares taxed at 28%
Spain (Beckham Law)
24% flat rate (6 years)Advantages
- Beckham Law: 24% flat rate on Spanish income up to ā¬600k (6 years)
- Popular for employees and self-employed
- High quality of life, good infrastructure
Considerations
- Scheme applies primarily to active income from Spain
- Passive investment income treated differently
- After 6 years standard Spanish progressive rate applies (up to 47%)
What does not change when you emigrate?
Emigration is not a fiscal clean slate. The Netherlands retains taxing rights in a number of cases, even if you live elsewhere.
Real estate in the Netherlands
Dutch real estate always remains in Box 1 or Box 3 of the Dutch tax return, regardless of your place of residence. Based on virtually all tax treaties, the Netherlands has the right to tax immovable property located on Dutch soil.
Fiscally facilitated pension
Pension accrued in the Netherlands with tax relief is generally subject to Dutch or treaty-country taxing rights upon payment, depending on the applicable tax treaty. Taking a pension to a low-tax country is rarely as simple as it sounds.
Box 2 after emigration (conserverende aanslag)
As described above: the conserverende aanslag remains outstanding until the shares are sold and tax settled. You cannot emigrate and then pay out BV profits tax-free.
For whom is emigration a realistic alternative?
More likely to make sense for
- High wealth (ā¬500k+), where tax savings are substantial
- Remote workers or retirees without Dutch income ties
- Those who already want to emigrate for other reasons
- Entrepreneurs relocating their business
Less likely to make sense for
- Employees with a permanent Dutch contract
- Smaller assets (<ā¬200k), where costs outweigh savings
- Real estate investors with significant Dutch property
- DGA shareholders with complex BV structure and conserverende aanslag
The Dutch Tax Authority scrutinises emigrations carefully. A formal deregistration from the municipality is not sufficient: if your social and economic life largely remains in the Netherlands, you may continue to be considered a Dutch tax resident. Have your situation assessed by a specialist tax adviser.