+4.10%
+9.27%
+6.43%
+0.44%
+8.60%
+7.99%
What The Law Actually Covers
The reform splits Box 3 into two regimes. Liquid assets, including listed shares, ETFs, bonds, and cryptocurrency, fall under a capital growth tax (Vermogensaanwasbelasting) taxing the yearly change in market value at 36%, with the first 1,800 euros per person exempt and losses carried forward indefinitely. Real estate and startup shares fall under a separate capital gains tax, taxed only when sold. Anyone holding 5% or more of a private company sits in Box 2, untouched by this reform, meaning the LinkedIn post describing a founder’s stake being valued and taxed on paper does not match how the law as drafted would apply to that situation.
The Real Pressure Points
The genuine concern is narrower than the viral framing but still significant for crypto and equity investors. A portfolio that rises sharply on paper, then falls before the holder can realize it, creates a tax bill on value that never materialized as cash, with no refund mechanism beyond carrying the resulting loss forward against future gains. 2025’s crypto regulatory shifts already signaled this kind of valuation-based scrutiny was coming across Europe, and Norway tightened its own exit tax in 2024 partly in anticipation of capital moving in response to exactly this kind of policy.
Planning Ahead Without Panic
For those genuinely exposed once the law takes effect in 2028, several legal approaches exist. Holding crypto or securities through a company structure shifts taxation to corporate rates and Box 2 rules rather than annual mark-to-market Box 3 treatment, though this carries its own compliance costs. Borrowing against appreciated assets rather than selling, the strategy long used by wealthy holders in the US and elsewhere, generates liquidity without triggering a disposal, though it does not avoid Box 3’s growth-based calculation since the asset value itself is what gets taxed, not the sale. Relocating before January 2028, as some founders cited in early coverage are already doing, avoids the regime entirely but triggers exit tax considerations depending on destination, and Belgium’s milder 10% realized-gains tax starting 2026 is drawing comparison as a softer landing within the EU.
The more durable signal is regulatory, not personal. The EU’s shift of crypto oversight to ESMA in Paris and ongoing disputes between national regulators over supervision authority show Brussels and member states are still negotiating who sets the rules for exactly the asset classes Box 3 targets. Until the Eerste Kamer votes and the coalition’s promised realized-gains replacement takes shape, the most accurate plan is to track the Senate timeline rather than react to a headline describing a law that has not yet passed.
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