Heinen revises Box 3 bill after Senate resistance - 2028 implementation date uncertain
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Timeline

Box 3 Timeline

The complete history of Box 3: from the forfaitaire system in 2017 to the revision announced by minister Heinen in 2026.

Court ruling
Legislation
Breaking
Future
2017

New forfaitaire Box 3 system introduced

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.

24 december 2021

Christmas ruling: Supreme Court declares forfaitaire system unlawful

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.

Februari 2022

Legal redress offered to objectors

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.

2023

Bridging system introduced (actual asset split)

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.

6 juni 2024

Supreme Court: non-objectors also entitled to actual return taxation

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.

Najaar 2024

Bill 36.748 submitted to Lower House

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.

12 februari 2026

Lower House approves bill

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.

24 februari 2026

Senate begins review

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.

25 februari 2026

Heinen announces bill revision

Breaking

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.

17 maart 2026

Ministry technical briefing (scheduled)

The Ministry of Finance gives a technical briefing to the Senate Finance Committee. Given Heinens announcement to revise the bill, it is unclear whether and how this briefing proceeds in its current form.

Voorjaar 2026

Senate vote (uncertain)

After the revised bill, the Senate must go through the full legislative process again: written preparation, possibly expert hearings, plenary debate and vote. The previously mentioned May 2026 target is no longer realistic following Heinens announcement.

1 januari 2028

Intended effective date (uncertain)

The originally intended implementation date of the Wet Werkelijk Rendement Box 3. With the announced bill revision and a new Senate round, the feasibility of this date is uncertain. A shift to 2029 or later is possible.

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