{"type":"document","data":{"id":"7483ec99-276a-4d90-863a-0a8a1a033688","localeString":"en-GB","publishDate":"2025-12-24T11:31:15.214+01:00","contentType":"onecms:productPage","hasMacro":false,"flexPageMetadata":{"afmBanner":false,"robotInstruction":{"noIndex":false,"noFollow":false},"description":"Lower Box 3 taxation on real estate held through a STAK structure (Stichting Administratie Kantoor). Read more here."},"mainHeaderZone":{"componentType":"productHeader","coreHeader":{"body":"Do you want to purchase private investment property? And are you seeking new avenues to optimise your Box 3 tax position in the Netherlands? The current transitional regime for Box 3 has introduced significant changes to the landscape. Notably it is no longer possible to deduct Box 3 debts from your deemed return base: a key difference from previous rules. As a result property investors may now find themselves liable for substantially higher Box 3 taxes than in the past.","headerImage":{"transformBaseUrl":"https://assets.ing.com/transform/f7f69a85-d5a6-4f09-b7f2-55a0af82b58c/Woman-in-casual-clothing-sits-on-the-sofa-looking-at-her-mobile-phone","type":"image","width":5627,"original":"https://assets.ing.com/m/22b7cf0aceaca7f3/original/Woman-in-casual-clothing-sits-on-the-sofa-looking-at-her-mobile-phone.jpg","extension":"jpg"},"title":"Real estate and box 3: lowering your tax bill with a STAK structure?"},"backLink":{"textLink":{"url":"/en/private-banking/knowledge-and-insights/wealth-growth","text":"Grow your wealth"}}},"flexZone":{"flexComponents":[{"componentType":"paragraph","richBody":{"value":"

However, the STAK (Stichting Administratiekantoor) structure offers a potential solution. When box 3 real estate is held through a STAK the value of the certificates is taxed in Box 3 as ‘other assets’ in the hands of the certificate holder. The notional return rate on these assets currently stands at 6.00% (2026) [1]. Unlike direct property ownership a STAK arrangement allows you to set off the assets and liabilities within the STAK against each other when determining the fair market value for Box 3, potentially reducing your taxable base.

"}},{"componentType":"sectionTitle","title":"Consider the following example"},{"componentType":"paragraph","richBody":{"value":"

Suppose you are single and your only income is from Box 3: you own €2 million in leased office properties financed with €1 million of debt. If you hold the real estate directly, your Box 3 tax liability in 2026 amounts to approximately €31,530. By utilizing a STAK structure and certifying the real estate, your Box 3 tax drops to around €20,320: a tax saving of roughly €11,210 [2].

"}},{"componentType":"sectionTitle","title":"The perspective from the Secretary of State"},{"componentType":"paragraph","richBody":{"value":"

In early 2023 the Secretary of State for Taxation and the Tax Authorities confirmed that this outcome is indeed a consequence of the current Box 3 transitional regime. Legally the distinction is material: direct real estate ownership confers legal title whereas a STAK certificate holder has only economic rights. The Secretary emphasized however the STAK structure is not intended primarily as a tax avoidance vehicle. Accordingly, the Tax Authorities will closely monitor the use of such arrangements and assess whether additional legislative measures are warranted. 

"}},{"componentType":"sectionTitle","title":"Current status"},{"componentType":"paragraph","richBody":{"value":"

So far, no legislative amendment has been proposed that eliminates the STAK benefit, despite the announced stricter oversight. 


This article was written by Robert Mantel and Stef Goossens, Tax Exertise Managers.

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[1] There is a counter evidence scheme that allows taxpayers to demonstrate that their actual return is lower than the deemed return. See for more information: https://www.ing.nl/private-banking/kennis-en-inzichten/vermogen-laten-groeien/wet-tegenbewijsregeling-box-3[2] This does not take into account the gradual reduction of the general tax credit (''afbouw algemene heffingskorting'').

"}},{"componentType":"accordion","accordionList":[{"title":"Based on the situation as of December 24, 2025","richBody":{"value":"

This article assumes domestic tax liability, with real estate located in the Netherlands. The information provided by ING in this article is not an offer, advice, or financial service and is solely intended to inform you and provide practical tips. We always recommend consulting a specialist regarding your financial and/or wealth planning. This article has been compiled with the utmost care. However, it may contain inaccuracies or omissions. ING is not liable for any damage (of any kind) resulting from the use of the information provided. No rights can be derived from the information. Any rates mentioned are indicative and not binding for ING. All rights and changes reserved. This is a publication of ING Bank NV, registered in Amsterdam.

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