At a small accountant's table, Box 3 does not feel like a constitutional debate. It feels like a founder with a BV ledger on one side, a private investment account on the other, and one simple question: when does relief become real cash?
The cabinet still points to 1 January 2028 for a new Box 3 system based on actual return from assets. The Tweede Kamer adopted the Wet werkelijk rendement box 3 on 12 February 2026. The Eerste Kamer still has to deal with it. In the meantime, the government is still examining changes inside the vermogensaanwasbelasting model and studying vermogenswinstbelasting as a separate route.
A design choice with a cash shadow
Those two Dutch words matter because they move the tax burden in different ways. Vermogensaanwasbelasting, or VAB, taxes annual value growth. Vermogenswinstbelasting, or VWB, taxes the gain when the asset leaves the taxpayer's wealth, usually on sale.
That difference is not abstract. VAB fits reporting systems and bank data more easily. VWB fits the cash moment better, because the tax follows a sale. Official legislative material gives VWB the advantage on liquidity and public acceptance. It also lists lock-in, construction sensitivity, long record keeping, and budget cost as trade-offs.
For a small agency owner, this is not theory. The company accounts may be tidy. Salary, VAT, invoices, and payroll may all be under control. Privately, the same owner may hold securities, a shared inherited home, a loan to a friend, and crypto bought years ago. The company file is one line. The private file is a stack.
The refund queue is not a bank balance
The current counterproof route already shows how slow relief can be. Until the new legislation starts, Belastingdienst uses the fictitious return unless the actual return is lower under the counterproof scheme. Actual return covers interest, dividends, and value changes. It is calculated over total assets, without the heffingsvrij vermogen.
The year still matters. Positive and negative results are netted within one year. If the total actual return is negative, it is set at zero. Under the current route, that loss does not move to another year. For an owner who expected a reduction, that changes the timing more than the headline.
The scale is large. The 30 June 2026 progress update says Box 3 recovery work covers tax years 2017 to 2024. Up to May 2026, almost 7.2 million letters had gone out. That included 4.26 million invitations to submit an Opgaaf werkelijk rendement. Another 3.7 million invitation letters are expected during 2026 and 2027.
By 8 June 2026, 804,411 forms had been submitted. Of those, 34,500 had been substantively processed, with a budgetary impact of €22.5 million. The work will continue at least until 2030. For a founder or owner-manager, that is not a side note. It means any expected reduction still sits in the queue until the decision arrives.
Finality still matters
The court track has also become clearer. On 25 June 2026, the Hoge Raad ruled in ECLI:NL:HR:2026:907 on the Massaal bezwaar plus question for Box 3 years 2017 to 2020. The case concerned taxpayers whose assessments had already become final before the Kerstarrest and who had not objected within six weeks.
The Hoge Raad confirmed that non-objectors are not in the same legal and factual position as timely objectors. Belastingdienst has said the practical result plainly: people who did not object, or objected too late, have no right to Box 3 legal restoration for those years.
That is not a moral verdict on taxpayers who missed the deadline. Many did. It is a reminder that tax relief lives inside procedure. Politics can move on while the door for one file has already closed. For small businesses, that is a familiar rule. A good argument after the deadline is still late.
Records are becoming the private discipline
The next system leans harder on data. Domestic financial-institution data is used as much as possible for the pre-filled income tax return. Foreign account data through CRS and FATCA is affected by timing and quality issues, so it is used more as contra-information. From 2027, automatic exchange of crypto-asset data starts under DAC8, with the aim of moving toward pre-filled crypto data.
That makes private record keeping more important, not less. Bank switches, foreign brokers, portfolio transfers, marriage in community of property, inheritance, divorce, start-up shares, property, and crypto wallets can all create gaps. A clean annual statement may not close them. An owner still needs the acquisition values, sales, dividends, interest, debts, and dates that sit behind the numbers.
For founders and owner-managers, the real file now has three layers. First, the years involved. Second, the procedural position of the old assessments. Third, the private asset inventory. Expected relief belongs in a different box from short-term cash planning until the decision is in hand.
The business lesson is simple
Box 3 is still a political argument. It is also becoming a record-keeping and liquidity file beside the company accounts. The reform may create a closer link with actual return. The waiting room, the court boundary, and the data burden remain part of the same reality.
Calm is the right posture here. Not passivity. Just the kind of calm that keeps dates, records, and cash apart until the tax system has caught up with its own promise.
Want to check your Box 3 position before it hits cash planning?
The data, sourcing, and analysis behind this article were conducted by Linda Pavan. 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 before publication.
References
- Documenten openbaar over besluitvorming box 3 - Taxence
- Rijksoverheid - 2028 actual-return system remains the official route
- Rijksoverheid - Official timeline and political movement
- Rijksoverheid / Open Overheid - March 2026 letter on adjustments, loss carry-back, and VWB development
- Rijksoverheid / Open Overheid - Hybrid system: VAB versus VWB trade-offs
- Belastingdienst - Actual return under the current counterproof route
- Belastingdienst - Processing time for Opgaaf werkelijk rendement
- Rijksoverheid / Open Overheid - Latest progress report on Box 3 recovery
