Partial Non-Resident Status Abolished: Box 3 Impact on the 30% Ruling
What Was Partial Non-Resident Taxpayer Status?
The Dutch income tax system sorts income into three "boxes". Box 1 covers wages, pension and the imputed rental value of your own home. Box 2 covers income from substantial shareholdings (holdings of 5% or more in a company). Box 3 covers savings and investments - bank balances, brokerage accounts, crypto, second homes abroad, rental property, and so on.
Ordinarily, a Dutch resident is taxed in all three boxes on their worldwide assets and income. But until the end of 2024, 30% ruling holders could make a one-line election on their Dutch tax return and be treated as a partial non-resident taxpayer (partiële buitenlandse belastingplicht). The effect: for Box 2 and Box 3 purposes only, you were treated as a foreigner. Dutch tax did not apply to your foreign bank accounts, foreign brokerage holdings, foreign rental properties, or foreign company stakes.
For an expat arriving with a substantial portfolio, this was often worth more than the 30% wage exemption itself. A €500,000 investment portfolio held through a broker in your home country produced zero Dutch tax. The same portfolio today can generate a Dutch tax bill of several thousand euros a year.
What Changed on January 1, 2025
As part of the 2024 Belastingplan, the Dutch parliament abolished the election for partial non-resident taxpayer status. From January 1, 2025, new 30% ruling holders can no longer elect this treatment. For most existing holders, the election also ended on that date - meaning their foreign Box 2 and Box 3 assets became taxable in the Netherlands from 2025 onward.
The 30% wage exemption on your salary is unaffected - that benefit continues for the duration of your ruling (at the rate that applied when your ruling was granted). The change is narrow but consequential: it closes the Box 2 / Box 3 side door, not the Box 1 wage benefit that is the ruling's headline feature.
From 2025, a 30% ruling holder is taxed as a full Dutch resident on worldwide income and assets. That means your Spanish apartment, your US brokerage account, your Singapore savings and your German rental property are all back on the Dutch tax return - even if you never touch the money while living here.
How Box 3 Actually Works
Box 3 does not tax your actual investment income. Instead, it taxes a notional return - the forfaitair rendement - calculated by asset type on the value held on January 1 of the tax year. For 2026 the notional returns are approximately:
| Asset Type | Notional Return (2026) | Examples |
|---|---|---|
| Savings | ~1.44% | Bank balances, savings accounts |
| Other assets | ~5.88% | Stocks, ETFs, crypto, second homes, lending |
| Debts | ~2.61% (deductible) | Mortgages on Box 3 property, personal loans |
The notional return across all your assets is summed, a tax-free allowance of €57,684 per person (2026) is subtracted, and the remainder is taxed at 36%. Savings rates are updated in January 2027 based on actual market rates, so 2026 figures are provisional.
A separate werkelijk rendement (actual return) system, prompted by Hoge Raad rulings that found the old forfaitair rendement unlawful for many taxpayers, is under development and expected from 2028. Until then, the provisional system above applies.
Worked Example: Maria's Portfolio
Numbers make the impact concrete. Meet Maria - a fictional software engineer who moved from Barcelona to Amsterdam in 2024 and has an approved 30% ruling. She holds:
- €40,000 in a Spanish savings account
- €210,000 in a broker account holding a global ETF portfolio
- A €320,000 apartment in Barcelona that she rents out (no mortgage)
Before 2025 vs. From 2025
Under partial non-resident status (2024 and earlier):
Box 3 tax on Spanish savings, ETF portfolio and Barcelona apartment: €0. All three assets were foreign-situs and the election exempted them from Dutch Box 3.
Under full Dutch resident status (2026):
Total assets: €40,000 + €210,000 + €320,000 = €570,000
Less tax-free allowance (heffingvrij vermogen): - €57,684
Taxable capital: €512,316 (89.9% of total)
Notional return: €40,000 x 1.44% + €530,000 x 5.88% = €31,740
Taxable portion of notional return: €31,740 x 89.9% = €28,534
Box 3 tax at 36%: roughly €10,272 per year
Under partial non-resident status, Maria paid none of that. The ~€10,000 annual tax bill on assets that generate no Dutch-sourced income is pure new cost - and it scales quickly. Double the portfolio and the bill roughly doubles.
The €57,684 allowance (€115,368 for tax partners) only cushions the first slice. Once total assets exceed that threshold, the notional-return calculation applies proportionally - which means larger holdings, like inherited homes, accumulated investment accounts or shares in a foreign startup, are where the change really bites.
Who Is Most Affected
Foreign property owners
If you own a home or apartment abroad that is not your principal residence, it sits in Box 3 at market value. Mortgages on that property are deductible in Box 3 at the debt rate, but rental income itself is not separately taxed - only the notional return on the equity value. Even so, high-value property tips most people well over the allowance.
Expats with substantial investment accounts
ETF portfolios, brokerage accounts, mutual funds and shares held abroad are all Box 3 "other assets". A €400,000 portfolio at 5.88% notional produces €23,520 of taxable return - enough to consume the allowance and generate real tax.
Substantial shareholders (Box 2)
If you hold 5% or more in a foreign company, dividends distributed and gains on sale now fall into Dutch Box 2, taxed at 24.5% on the first €67,804 of income and 31% above that (2026 rates). Under the old rules, foreign substantial holdings produced no Dutch tax - full stop.
Crypto holders
Crypto is treated as a Box 3 "other asset" regardless of where the wallet or exchange is located. Previously, assets held on a non-Dutch exchange were effectively out of reach. Now the entire balance at January 1 each year enters the notional-return calculation.
Transitional Rules: Do You Still Qualify?
There is one narrow transitional rule, and it matters if your ruling is old. If your 30% ruling application was filed before January 1, 2024, you can continue to elect partial non-resident status through the end of 2026. From 2027 onward, even pre-2024 filers lose the election.
In practice, this transitional rule is disappearing. Anyone granted a ruling in 2024 or later never qualified. Anyone with a pre-2024 ruling has at most two tax years left (2025 and 2026) to benefit. After 2026 the rule is dead regardless.
The transitional rule is linked to when the application was filed, not when it was approved. If your employer filed in late 2023 and approval came in 2024, you still qualify for the transitional rule through 2026. Find the filing date in the original correspondence with the Belastingdienst.
Practical Steps You Can Take Now
1. Make an inventory of your foreign assets
Pull together year-end statements for every account, property deed, crypto wallet and private company holding you own outside the Netherlands. You need the value on January 1 each year - start tracking this now, because the Belastingdienst will ask.
2. Review your tax partner situation
The Box 3 allowance is per person (€57,684 in 2026, so €115,368 for a couple). Assets can be allocated between tax partners freely on the return. If one partner is well below the allowance, shifting assets to their side reduces the taxable base.
3. Consider the timing of asset sales
Box 3 tax is based on value on January 1. Selling down positions in December and holding cash (or gold, which is treated as savings) can lower the following year's base. Do not let tax drive investment decisions alone, but be aware of the mechanic.
4. Consult a Dutch tax advisor before restructuring
Options like transferring assets to a holding company, gifting to family, or moving investments into a Dutch pension vehicle all have anti-abuse rules attached. These work for some people and backfire for others - a consultation with an advisor who can see your full position is worth the fee.
5. Keep applying for the 30% ruling if you qualify
Losing the Box 2 / Box 3 election does not make the ruling worthless. The Box 1 wage benefit alone is typically worth €6,000 to €20,000 per year depending on salary - money you won't leave on the table. Use our calculator to estimate the wage-side savings for your situation.
The Wage Benefit Is Still Worth Claiming
Box 3 has changed, but the core 30% (or 27% from 2027) exemption on your salary is alive and worth thousands per year. We prepare and file your application correctly the first time.
Frequently Asked Questions
Does this affect my 30% wage benefit?
No. The abolition of partial non-resident status is a separate change to the same reform package. The 30% (or 27%) exemption on your salary continues exactly as before. Only the Box 2 and Box 3 election on foreign assets is gone.
What about assets I held before I moved to the Netherlands?
Pre-arrival assets are still taxable once you become a Dutch resident and the partial non-resident election is no longer available. The step-up for Box 2 substantial holdings - which resets your tax cost base to market value on the day you became a Dutch resident - is still available. Box 3 has no step-up because the system taxes a notional return on value, not capital gains.
Do I need to file a Dutch tax return on my foreign investments now?
Yes. As a Dutch tax resident you must declare worldwide assets in Box 3 and worldwide substantial shareholdings in Box 2. Failure to declare foreign assets attracts separate penalties, and the Belastingdienst receives automatic information from most EU countries and many others under the Common Reporting Standard.
Can I still use partial non-resident status if my ruling started in 2023?
Yes, through the end of 2026. If your 30% ruling application was filed before January 1, 2024, the transitional rule lets you continue electing partial non-resident status on your 2025 and 2026 returns. From the 2027 tax return onward, the election is unavailable to everyone.
Does this change apply to foreign pension income in Box 1?
No. Pension income from a foreign scheme is Box 1 income and was never covered by the partial non-resident status election. Treaty rules between the Netherlands and the paying country determine where that pension is taxed - that framework is unchanged.
Will the Box 3 system itself change?
Yes. Following Hoge Raad decisions that found the old system unlawful for taxpayers whose actual returns were below the notional rates, a new werkelijk rendement (actual return) system is in development and expected to take effect from 2028. Until then, the forfaitair rendement figures above apply, with an option to claim actual return if it is demonstrably lower. Speak to an advisor if your actual return is well below 5.88%.