Wet Werkelijk Rendement

The Netherlands introduces a new system assigning separate fictitious returns to savings, investments, and debts. Intended as a closer approximation of actual returns than the flat 4% previously used, the system ends up overtaxing savers during the low-interest-rate era.

The Supreme Court rules in the so-called Christmas ruling that the forfaitaire Box 3 system violates the right to property and the prohibition of discrimination under the European Convention on Human Rights. The ruling applies to taxpayers who filed timely objections.

The Tax Authority offers redress to taxpayers who had filed timely objections for 2017-2020. Those who had not objected are excluded - which later leads to further litigation.

Pending a permanent fix, the government introduces a temporary bridging system. Fictitious returns are now set per asset class based on actual market figures. Investments retain a relatively high forfait, but savings rates better reflect actual interest.

The Supreme Court extends the reach of the Christmas ruling: even taxpayers who did not object can claim taxation based on actual returns when the forfait is higher. This potentially affects millions of assessments and creates enormous pressure on the legislative process.

The government submits bill 36.748 (Wet Werkelijk Rendement Box 3) to the Lower House. The proposal introduces a hybrid system: wealth accretion tax on investments (including unrealised gains) and a realisation-based tax for real estate. Intended effective date: 1 January 2028.

A majority of the Lower House approves bill 36.748. In favour: SP, GroenLinks-PvdA, D66, Volt, PvdD, CDA and VVD. Against: 50PLUS, DENK, SGP, ChristenUnie, JA21, BBB, Groep Markuszower, PVV and FVD. A motion is also passed requesting the government to submit an alternative vermogenswinstbelasting proposal before Prinsjesdag 2028.

The Senate Finance Committee discusses the procedure for reviewing bill 36.748. A technical briefing with the Ministry of Finance is scheduled for 17 March 2026. Several Senate groups signal a critical stance.

Minister Heinen announces he is going back to the drawing board with the Box 3 bill. Following a wave of investor protests and critical Senate remarks, he announces revisions. What exactly will change is not yet known. The 1 January 2028 implementation date is now under pressure.

The Lower House passes a motion (ChristenUnie + JA21, with VVD support) calling on the government to include loss carry-back provisions in the revised Box 3 bill. If an investor suffers a loss in a given year, that loss should be offsettable against tax paid in the previous year.

The Senate Finance Committee holds oral consultations with State Secretary Eerenberg. Outcome: the cabinet confirms it is actively exploring a carry-back provision (offsetting losses against prior years), potentially included in Tax Plan 2027 via an amendment. A separate bill for start-up entrepreneurs is also in preparation. Eerenberg acknowledges the process was 'not optimal' but continues with regular parliamentary procedure. The 2028 effective date remains the official target.