What the Box 3 Changes Mean for Your Dutch FIRE Plan

The Box 3 overhaul has been coming for years. Now that the Tweede Kamer has passed the new law (February 2026) and a 2028 implementation date is on the table, it's worth thinking through what it actually means for FIRE planning in the Netherlands.

The short version: it's complicated, still evolving, and the honest answer is "it depends on your situation." But there are some clear directional shifts worth understanding now.

Quick Recap: How Box 3 Affects FIRE Today

Under the current transitional system, Box 3 works on deemed returns:

• Bank savings: ~1.44% assumed return

• Investments (ETFs, stocks): 5.88% assumed return

• Tax rate: 36% on the deemed return

For a FIRE investor with most assets in equities, this creates roughly 2% annual drag on portfolio value — regardless of what markets actually do.

That drag is the reason Dutch FIRE planning typically uses a 2–2.5% withdrawal rate rather than the 4% you see in most international FIRE content. It's also why the bridge strategy (sizing for gap years, not forever) makes more sense here than pure drawdown.

What the 2028 System Changes

The new Wet werkelijk rendement box 3, passed by the Tweede Kamer on 12 February 2026, replaces deemed returns with actual returns. Here's what shifts:

You pay tax on what you actually earn (mostly)

For savings accounts: straightforward. Tax on actual interest received.

For investment portfolios: this is where it gets nuanced. The current approved bill uses a capital growth tax(vermogensaanwasbelasting) — annual taxation of both income received (dividends) and changes in portfolio value, including unrealised gains.

This means: if your €200,000 portfolio grows by €14,000 in a year, you'll owe 36% of €14,000 = €5,040 — even if you didn't sell anything.

The tax-free structure changes

Out: the €57,684 tax-free capital threshold (2025 amount). In: a €1,800 annual tax-free return.

This is a big structural shift. Previously, if you kept your wealth below the threshold, you paid nothing. Under the new system, everyone pays once their actual return exceeds €1,800 — regardless of portfolio size.

For small investors with modest portfolios, this could actually be better — a €40,000 portfolio that earns 4% (€1,600) would owe nothing. For larger FIRE portfolios, the threshold disappears as a planning tool.

Losses can be carried forward

One genuinely positive change: annual losses above €500 can be carried forward indefinitely to offset future gains.

Under the current system, a bad year is just a bad year — you might still owe little or no tax if your actual return is below the deemed rate, but there's no formal loss carryforward. Under the new system, a year where your portfolio drops €20,000 creates a €20,000 loss that reduces your taxable gains in future years.

For long-term investors going through a market downturn, this is real protection.

Does Your FIRE Number Go Up or Down?

The honest answer: for most Dutch FIRE investors, it probably stays roughly similar in good market years, but gets meaningfully better in bad ones.

Here's the logic:

Current system (2025): You pay 5.88% × 36% = ~2.12% drag per year, always, regardless of returns.

New system (from 2028): You pay 36% on actual return. If markets return 7%, you pay ~2.52% drag. If markets return 3%, you pay ~1.08% drag. If markets drop, you pay nothing and build a loss carryforward.

Average equity returns historically run around 6–8% per year. At 7%, the new system produces slightly more tax than the current deemed system. But the variance is completely different — you're no longer paying full tax in bad years, and the loss carryforward gives you a cushion.

Practical implication for FIRE planning:

The 2% drag assumption that underlies most Dutch FIRE calculations won't change dramatically in normal market conditions. You probably don't need to dramatically revise your FIRE number upward or downward. But sequencing risk — the danger of markets falling early in retirement — becomes somewhat less dangerous, because bad years generate loss credits rather than tax bills.

The Unrealised Gains Problem for FIRE Investors

This is the specific issue that most directly affects people in the accumulation phase and early retirement.

Under the approved bill, if your ETF portfolio grows by €15,000 in a year — even if you're trying not to sell anything to minimise tax events — you owe 36% × €15,000 = €5,400.

You need to pay that tax from somewhere. For working investors still earning income, this is manageable. For early retirees living off their portfolio, it could mean selling assets to pay the tax bill — even in years where selling wasn't part of the plan.

This is the main reason a parliamentary majority has already asked the government to move toward realised gains onlybefore 2028. Whether that happens before the current law takes effect, or becomes a revision shortly after, is genuinely unclear.

The practical advice right now: don't restructure your portfolio around the 2028 rules until the Senate has voted and the final shape is confirmed. The law as approved is already likely to change before it takes effect.

What About Expats?

There's a separate change worth knowing about if you're an expat using the 30% ruling.

Until 2024, expats with the 30% ruling could opt for "partial non-resident status," which meant your Box 3 assets outside the Netherlands were excluded from Dutch wealth tax. That option has been abolished from 2025 onwards.

From 2025, if your 30% ruling is active and started in 2024 or later, you're taxable on your worldwide Box 3 assets under Dutch rules. No exemption for foreign savings or investments.

This doesn't change the Box 3 calculation mechanics, but it significantly widens the base — expats with substantial assets in their home country now have those in scope too.

If you acquired the 30% ruling before 2024 and were already using partial non-resident status in 2023, you get a transitional arrangement until the end of 2026. After that, it's gone.

The OWR Form: Something You Can Do Right Now

While all the 2028 debate plays out, there's a practical action available today.

Since July 2025, the Opgaaf Werkelijk Rendement (OWR — Actual Return Statement) form lets you declare your actual Box 3 return for past years. The Belastingdienst uses the lower of your actual or deemed return.

If 2022 was a losing year for your portfolio — and for most equity investors it was — you may have overpaid Box 3 tax. The form can be used retroactively back to 2017 in some cases (where assessments weren't already finalised before December 2021).

For a FIRE investor with a €400,000 portfolio, the difference between a -10% actual return and the +5.88% deemed return is a potentially significant refund.

Worth checking. The form is available at belastingdienst.nl.

What to Actually Do With This Information

Don't panic-restructure. The 2028 rules are still being debated and amended. Rebalancing portfolios now based on a law that parliament has already signalled it wants to revise would be getting ahead of the facts.

Do keep proper records from now. Under the new system, knowing your cost basis (what you paid for each holding) will matter for calculating actual gains. If you haven't been tracking this, start now. Most brokers (DEGIRO, IBKR) can provide historical transaction data.

Do check the OWR form for bad years. The current tegenbewijsregeling is real money if your actual returns were below the deemed rate. 2022 especially.

Do revisit your FIRE number once the law is finalised. The structural changes (€1,800 free return instead of capital threshold; loss carryforward; unrealised gains taxation) will shift planning assumptions somewhat. Wait until the Senate has voted before rebuilding your model.

Do factor in the accumulation vs drawdown difference. The unrealised gains issue matters more during early retirement drawdown than during accumulation. If you're 10+ years from retirement, the final shape of the law is more important than the current draft.

Frequently Asked Questions

Will the Box 3 changes make FIRE easier or harder in the Netherlands? Probably neither dramatically, in normal market conditions. The 2% annual drag on ETF portfolios may shift slightly up in good years, but bad years become materially less costly due to loss carryforward. The bigger impact is psychological — paying tax on unrealised gains during early retirement requires liquidity management that the current system doesn't.

Do I need to change my FIRE calculator assumptions now? Not yet. Wait until the Senate has voted and the final form of the 2028 law is confirmed — parliament has already indicated changes are coming. There's no point recalculating based on a law that's already being amended.

Will the 4% withdrawal rule work in the Netherlands under the new Box 3 system? No — and it still won't after 2028. Even with actual return taxation, the combination of Dutch living costs, inflation, and 36% tax on investment gains means 2–2.5% remains the realistic Dutch withdrawal rate range.

What is the new Box 3 tax-free allowance from 2028? The current proposal replaces the capital threshold (€57,684 in 2025) with a €1,800 annual tax-free return. No Box 3 tax is owed if your total actual return from all assets falls below €1,800.

When will I know the final rules for Box 3 from 2028? The bill passed the Tweede Kamer on 12 February 2026 and is now before the Senate. If the Senate passes it without major amendments, the rules should be confirmed well before the end of 2026. Monitor belastingdienst.nl and rijksoverheid.nl for updates.

---

This article reflects legislative information as of April 2026. The Box 3 law is still being reviewed by the Senate and may be amended before taking effect. Always verify current rules at belastingdienst.nl.

→ Curious how different Box 3 scenarios affect your Dutch FIRE number? Try the calculator to model your specific situation