That is the question investors have been focused on in recent weeks. A Box 3 bill was ready under which you would pay tax each year on increases in the value of your investments, even if you had not sold anything. In other words, you would pay tax on gains that exist only on paper. The bill still has to pass the Senate and has not yet entered into force. Following fierce criticism, the government proposed an amendment to the legislation.

The amendment was initially well received. For shares, bonds and ETFs, the government has opted to tax gains when they are realised through a sale, rather than taxing annual increases in value. That appeared to be a step in the right direction.

However, physical gold and silver, whether held at home or in storage, as well as directly held crypto assets, fall outside this amendment. For these assets, tax on annual increases in value would remain in place until 2030.

This means that you would pay tax for as long as you hold gold and its value rises, even if you do not sell it. Under the latest proposal, the rate was 36% of the annual increase in value. No tax would be due on the first €1,000 of annual returns (this amount may be increased). Losses could be offset against gains in later years.

Why is physical gold treated differently from shares under the Box 3 amendment?

For the amendment, the government has to work with the legislation passed by the House of Representatives in February. That legislation already included an exception for shares in start-ups and scale-ups. The government can quickly extend that exception to all shares, bonds and similar investments. According to State Secretary for Finance Eerenberg, however, this did not provide the necessary legal basis for all types of investments.

“Crypto, cognac, gold, silver or Pokémon cards – all sorts of other things people might invest in – were not included in the legislation,” Eerenberg said during the General Financial Debate.

Unfair treatment of gold and crypto under the Box 3 amendment?

It is unusual that, from 2028, one type of investment would be taxed annually on increases in value, while another would only be taxed on gains when sold. Eerenberg himself acknowledges that this is the result of the rush to introduce the new system. Asked why crypto held through an exchange-traded product would be taxed differently from crypto held directly, he said: “At some point, it is one or the other. Either we want to take the fastest possible route together, which comes with limitations such as this one, or the House says it wants a broader discussion, but then we will not get to it until 2030.”

Because speed is the government’s priority, Eerenberg places gold and crypto in the same category as cognac and Pokémon cards. According to the government itself, these assets account for around 10% of invested wealth.

But there is a reason why De Nederlandsche Bank holds more than 612 tonnes of physical gold, worth €72.2 billion at the end of 2025, and why central banks around the world continue to buy physical gold. Physical gold is a crucial asset in times of geopolitical uncertainty. That is why countries maintain gold reserves, rather than cognac reserves or Pokémon card reserves. And that is why De Nederlandsche Bank holds physical gold rather than, for example, shares in a gold mining company.

If both chambers of parliament approve the bill and the amendment before 31 December, the new Box 3 system will take effect in 2028. The legislation, including the amendment, is regarded as an interim step. A separate law will still be required for gold, silver and crypto to be taxed only upon sale from 2030 onwards. If that legislation is delayed, the interim system is likely to remain in place for longer.

The concern, of course, is that nothing is quite as permanent as a temporary solution.

What are the chances that the Box 3 bill will pass?

It remains uncertain whether the Box 3 bill will be adopted in time. On 5 October, the Minister and State Secretary for Finance provided an explanation to the Senate, which raised a number of critical questions. Is it legally permissible to distinguish between directly held crypto (and gold) and other investments? How will the costs be covered? And can all of this really be implemented so quickly?

Minister Heinen is sticking to 2028, but acknowledges that implementation could be delayed until 2029. The Council of State cannot issue its advice on the amendment before the parliamentary debate on 12 October. Its opinion is expected no earlier than 19 October and possibly not until 26 October. Banks have said they do not have enough time to adapt their systems. As a result, tax returns for 2028 may not be pre-filled, leaving investors to work out more of the information themselves. There were already doubts about whether the Dutch Tax Administration would be able to implement the system in time.

Nevertheless, the government is doing everything it can to push the legislation through quickly. In response to concerns raised by the Senate, the Minister and State Secretary said they were trying to meet the call for a rapid solution.

What happens next with Box 3?

On 6 October, the House of Representatives voted on seven Box 3 motions. Almost all of them call on the government to protect savers and investors with relatively modest assets. Minister Heinen has promised to present a new proposal around 12 October, during the debate on the 2027 Tax Plan. This could also change the plans for 2027, including the reduction in the amount of assets that can be held in Box 3 without incurring tax.

Several important steps will follow:

• 19 or 26 October: advice from the Council of State on the amendment.
• By 1 November: the Dutch Tax Administration will indicate whether the plans are feasible to implement.
• Mid-November: the House of Representatives will vote on the Tax Plan.
• Before 31 December: the Senate must approve both the bill and the amendment.

If that final step is not completed, the current Box 3 system will remain in place for at least another year.

Is there also a petition calling for fair treatment of crypto in Box 3?

No, there is currently no petition, but there is a position paper published on 6 October by the Dutch Association of Crypto Service Providers (NVC) and Blockchain Netherlands. Holland Gold is one of the co-signatories. The Dutch crypto industry is concerned about the distinction created by the Box 3 amendment.

An exchange-traded product that tracks the price of bitcoin would only be taxed when sold. Bitcoin held directly, on the other hand, would be taxed each year on the increase in value. This could create a displacement effect, with investors feeling pushed by the tax system to exchange directly held crypto for an exchange-traded product that merely represents a claim on the issuer.

This article does not constitute tax advice. The plans have not yet been finalised.