Questions remain regarding taxation of savings and investment income. It remains highly uncertain whether this law will swiftly resolve all issues related to taxation of income from assets. The proposed capital growth tax differs from international norms, making it even more important to assess on a case-by-case basis what impact a taxpayer’s migration to another country has.
Before a bill comes into effect, it is reviewed by the House of Representatives (tweed kamerThe House of Representatives can approve, reject or propose amendments to the bill. If it is approved by the House of Representatives, it is sent to the Senate (Erste Kamer) for approval. The Senate can approve or reject the bill.
Looking ahead: consequences for migrants in the Netherlands
Expats living in the Netherlands who qualify as Dutch tax residents are generally required to pay tax on their worldwide income in the Netherlands. Previously, the partial non-resident regime largely exempted individuals with a 30% ruling (the ‘non-resident regime’) from Box 2 and Box 3 taxes, with a few exceptions. With the abolition of the partial non-resident regime (per 1 January 2025, and per 1 January 2027, for those entitled to the transitional legislation), all persons under the 30% regime will lose almost their total exemption from taxes on substantial shareholdings (Box 2) and on savings and investments (Box 3). Their worldwide income will be taxed in the Netherlands, provided they are considered Dutch tax residents, and the above changes in Box 3 will apply to them as well.
Considerations for employers, including globally mobile workers
The proposed changes are expected to affect the cost of the global-mobility program for employers with a tax-equalization policy (partially) covering income from savings and investments.
Employers who have questions about this amendment or how it may affect their (international) workforce situation may wish to consult their qualified cross-border professional or a member of the People’s Services team with Meijberg & Co. in the Netherlands (see Contact section).
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