KPMG MEIJBURG & CO INSIGHTS
General Assessment of and Next Steps for the Legislation
Questions remain around the taxation of savings and investment income. It remains highly uncertain whether this legislation will swiftly resolve all issues related to the taxation of income from assets. The proposed capital growth tax diverges from international norms which makes it even more important to assess on a case-by-case basis what the impact is of a taxpayer’s migration to another country.****
Before the bill can come into effect, it is reviewed by the House of Representatives (Tweede Kamer). The 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 (Eerste Kamer) for app…
KPMG MEIJBURG & CO INSIGHTS
General Assessment of and Next Steps for the Legislation
Questions remain around the taxation of savings and investment income. It remains highly uncertain whether this legislation will swiftly resolve all issues related to the taxation of income from assets. The proposed capital growth tax diverges from international norms which makes it even more important to assess on a case-by-case basis what the impact is of a taxpayer’s migration to another country.****
Before the bill can come into effect, it is reviewed by the House of Representatives (Tweede Kamer). The 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 (Eerste Kamer) for approval. The Senate can approve or reject the bill.
Looking Ahead: Consequences for Expatriates in the Netherlands
Expatriates residing in the Netherlands who qualify as Dutch tax residents are generally required to pay taxes on their worldwide income in the Netherlands. Previously, the partial non-resident regime allowed individuals with the 30% ruling (‘expat ruling’) to be largely exempt from Box 2 and Box 3 taxes, with certain exceptions. With the elimination of the partial non-resident regime (per 1 January 2025, and per 1 January 2027, for those entitled to transitional law), all individuals under the 30% ruling will lose their near-total exemption from taxes on substantial shareholdings (Box 2) and savings and investments (Box 3). They will be taxed in the Netherlands on their worldwide income, provided they are considered Dutch tax residents, and the above-mentioned changes to Box 3 will apply to them as well.
Considerations for Employers, Including Those with Globally Mobile Employees
The proposed changes are expected to impact global-mobility programme costs for employers with a tax-equalisation policy (partly) covering income from savings and investments.
Employers with questions about this amendment or how it might affect the situation of their (international) workforce, may wish to consult with their qualified cross-border tax professional or with a member of the People Services team with Meijburg & Co. in the Netherlands (see the Contacts section).