Netherlands Moves Toward Taxing Unrealised Bitcoin Gains Under New Wealth Regime

The Dutch government is advancing legislation that would overhaul how wealth, including bitcoin holdings, is taxed, replacing the current Box 3 scheme with a system based on actual returns rather than assumed ones. The proposal, approved by the Second Chamber (Tweede Kamer) in February 2026, is now being processed in the First Chamber (Eerste Kamer) and is planned to take effect on January 1, 2028.

Under the new model, taxpayers would be assessed on the real returns generated by their wealth each year, a departure from the Box 3 approach, which has long calculated tax liabilities using a fixed, presumed rate of return regardless of actual performance. Official documentation accompanying the proposal cites share price gains and cryptocurrencies as examples of the kind of indirect returns the new system is meant to capture.

This distinction matters for anyone holding bitcoin in the Netherlands. Rather than waiting until an asset is sold to apply tax, the government's model points toward taxing the annual appreciation in value of holdings such as bitcoin as it occurs, treating that increase as a form of income in the year it materialises.

What remains unresolved

The government's communication so far does not establish a specific tax rate for bitcoin, nor does it set out a particular mechanism for valuing BTC holdings for the purposes of the new regime. Those details have not been made public as part of the current proposal.

The draft does include a provision allowing losses incurred in a given year to be offset against Box 3 income in later years, a mechanism intended to soften the impact of taxing unrealised gains when asset values later decline.

Not all asset classes would be treated the same way. Real estate and shares in startups are set to be taxed differently under the reform, through a capital gains tax applied only at the point of sale, rather than on an annual basis. This creates an asymmetry between assets like bitcoin, potentially taxed on paper gains each year, and other holdings taxed only when actually disposed of.

Reform still in motion

The government has indicated it is still analysing possible modifications to the wealth increase component of the proposal, as well as alternative approaches based on taxing gains only at the point of realisation. This suggests the framework, while approved by the Second Chamber, is not yet fixed in its final form as it moves through the First Chamber.

For Dutch holders of bitcoin and other cryptocurrencies, the coming months of legislative review in the First Chamber will determine whether the annual-appreciation model survives intact, or whether the government shifts toward a realisation-based approach more consistent with how real estate and startup shares are set to be treated.