Box 3 neutralises the principal, but the annual 6% interest still needs cash, timing and proof.
A parent opens the family banking app in December. Somewhere else sits a notarial deed recording a €50,000 gift to an adult child. The parent kept the cash, while the child received a claim. The principal becomes payable after death, and the parent may revoke the gift.
On paper, the arrangement looks settled. One annual question remains alive: was the €3,000 interest actually paid?
That payment reaches beyond inheritance planning. It affects the current Box 3 calculation, leaves a bank trail and belongs in the tax reporting of both people. Entrepreneurs who keep company and private money apart will recognise the discipline, even in this family setting.
The principal and the return are different
The Belastingdienst knowledge group addressed this arrangement in KG:202:2026:12, published on 14 September 2026. Its example concerns a €50,000 notarial paper gift, 6% annual interest, payment of the principal after the donor’s death and a unilateral right of revocation.
Under the actual-return Box 3 calculation, creating the principal produces no capital growth for either party. Revoking it later has the same result. For the parent, creating the debt is a withdrawal. For the child, receiving the claim is a contribution. Revocation reverses those entries.
The arrangement still appears in the private wealth records. While it runs, the child has a receivable and the parent carries the matching debt. Both positions can matter in Box 3.
The rules separate changes in wealth from contributions and withdrawals. A family debt can therefore arise or disappear without creating capital growth in the actual-return calculation. The claim and obligation still need proper reporting and valuation.
Interest is where the cash speaks
Interest follows another route. In the knowledge group’s example, paid interest is a negative regular benefit for the parent and regular income for the child. The payment belongs to the year in which the money changes hands.
That word, paid, carries weight. Belastingdienst guidance requires at least 6% interest to be paid each year when a paper gift is intended to reduce the donor’s estate for inheritance-tax purposes. A ledger entry and a family understanding do not carry the same operational weight as money arriving in the child’s account.
Revocation leaves earlier payments where they belong. Interest paid before revocation keeps its Box 3 character. A later decision cannot rearrange the bank movements already made.
For a parent and child, that sounds obvious. In a private file left untouched for years, it can become the detail that separates a clean record from a difficult reconstruction.
A family arrangement is still governance
This is less a clever outcome about revocation than a lesson in responsibility. The deed creates a continuing relationship between two private balance sheets. One person records a debt, the other a receivable. One pays interest, the other receives it. Their tax returns should describe the same economic reality.
The useful question is simple: who checks whether the deed, payment, valuation and two tax returns still agree?
That question matters in founder households. Private liquidity competes with mortgage costs, tax reserves, investments and the wish to leave working capital inside the BV. A €50,000 paper gift produces €3,000 of interest for a full year.
The sum may be manageable. It remains a recurring cash commitment. Estate planning that cannot be funded reliably is weak planning.
The revocation clause adds another decision point. The knowledge group assumes that the right to revoke has no Box 3 value unless the holder intends to exercise it on the relevant valuation date. When revocation occurs, the decision, effective date, final interest payment and end of the receivable should form one coherent sequence.
Valuation cannot run on habit
Box 3 starts from value in the economic sense. Interest, term, security, repayment conditions and debtor risk can all affect the value of a private receivable or debt.
For the defined 6% paper-gift arrangement, the September position permits nominal valuation through a practical approach. That conclusion is specific to the arrangement. A different rate, maturity, payment pattern or enforceability profile can create a different valuation question.
Families should not carry an old private receivable at face value simply because it has always appeared that way in a spreadsheet. The terms still matter. So does the ability and intention to perform them.
A sound annual review places the deed beside the bank statements and both income-tax records. It checks the interest calculation, payment date, year-end value and any revocation decision. It also considers the household’s full Box 3 position, because actual return covers the relevant assets, debts, income and value movements together.
The government still targets 1 January 2028 for the Wet werkelijk rendement box 3. The calculation may change. Strong records will remain strong records.
Return to the December banking app. The important fact is not that the €50,000 principal remained unpaid. That was the arrangement from the start. The real test is whether the family continued to perform what the deed required.
A paper gift can defer the principal. It cannot defer responsibility for the cash, records and decisions that give the arrangement meaning.
If a paper gift forms part of your estate planning, we can review whether the deed, annual payments, valuation and tax records remain aligned.
The data, sourcing, and analysis behind this article were conducted by Linda Pavan Geraedts. AI was not used to identify sources, build the factual basis, or produce the analytical judgment contained here. AI was used only as a drafting aid. The final English text was personally reviewed, edited, and approved by Linda Pavan Geraedts before publication.
References
- KG:202:2026:12 Herroepelijke schuldigerkenning uit vrijgevigheid en box 3 | Kennisgroepen Belastingdienst
- Belastingdienst - Current Box 3 reporting and valuation of paper gifts
- Kennisgroepen Belastingdienst - Valuation discipline for private receivables and debts
- Belastingdienst - Inheritance-tax conditions and actual payment of interest
- Belastingdienst - Current actual-return counter-evidence regime
- Belastingdienst - Scope and finality of historic Box 3 recovery
- Rijksoverheid - Forthcoming structural Box 3 regime
