If you make a gift under guardianship, someone else manages the gifted assets on behalf of your children or grandchildren. Your child can only access or use these assets with the permission of the appointed guardian. You record this in a gift agreement. This can be done by notarial deed, but you can also arrange it yourself through a private deed. At ING Private Banking, it is possible to record a gift under guardianship using an ING private deed. We will then process this in our systems so that your child cannot independently access the bank account into which the gift has been deposited.
As the donor, you decide who will act as guardian. In practice, this is usually one of the parents. You also record the age until which the guardianship applies [1]. The gift agreement can include further provisions, for example a clause to help ensure that the gift cannot end up with the so-called ‘cold side’ of the family.
"}},{"componentType":"sectionTitle","title":"Gifting by debt acknowledgement"},{"componentType":"paragraph","richBody":{"value":"Gifting by debt acknowledgement is also referred to as a ‘paper gift’. You gift a sum of money to your children or grandchildren and immediately borrow this money back. Your children or grandchildren receive a claim on you, and you incur a debt to them. For legal and tax reasons, you must pay 6% interest on this debt to your children or grandchildren each year. The interest payment does result in an additional transfer of wealth from parent to child or grandchild without gift tax being levied. However, the interest must actually be transferred each year. You do not need to repay the debt until you die [2]. This means you retain access to the gifted amount yourself. This type of gift must be recorded by a civil-law notary.
Please note: The State Secretary for Finance and the Dutch government are considering significantly limiting or abolishing the tax advantages associated with a paper gift. In addition, it remains uncertain whether existing arrangements would be grandfathered and continue to be respected under any new rules. You can read more about this in our article.
Another option is to certify assets in combination with making gifts [3].
Certifying assets involves separating legal control from the economic interest. Shares are often certified, with control exercised by a foundation, or its board, while the original shareholders receive depositary receipts for shares. But you could also consider certifying your investment portfolio, real estate or an art collection. You retain control over the assets to be gifted through a trust office foundation, known in Dutch as a stichting administratiekantoor. You can then determine who will receive control after your death and/or when your children will gradually have more say.
You can gift depositary receipts over time, making optimal use of the annual gift tax exemption and, where applicable, the 10% gift tax bracket (see below), rather than gifting the asset in one go. Certification also keeps the assets together. This can offer economies of scale and ensures that all children share equally in the overall development in value. It can also be determined, among other things, that the depositary receipts giving entitlement to the underlying assets are not freely transferable.
"}},{"componentType":"sectionTitle","title":"Tax-free gifting in 2026"},{"componentType":"paragraph","richBody":{"value":"Would you like to make a tax-free gift to your children or grandchildren this year? You may gift up to €6,908 to each child without triggering gift tax. Amounts exceeding this exemption are subject to 10% gift tax up to €158,669. Any amount above this threshold is taxed at 20%.
For grandchildren, the exemption for 2026 is €2,769 per grandchild. Amounts above this exemption are subject to 18% gift tax up to €158,669, while any excess is taxed at 36%. In principle, the recipient of the gift is liable for any gift tax that may become due.
In short, would you like to gift wealth while retaining control? This is possible. There are several ways to make gifts in a controlled manner. Discuss them with your Relationship Manager. Conditions apply to every form of gifting. Ask your tax adviser or civil-law notary about the options that best suit you and your wishes.
"}},{"componentType":"paragraph","richBody":{"value":"[1] Your child may, after five years, petition the court to terminate the guardianship.
[2] The donor (who is also the borrower) has the option to repay all or part of the debt during their lifetime. Such a payment is simply a repayment of an existing debt and is not regarded as a new gift. Consequently, it does not constitute a separate transfer for gift tax purposes.
[3] In practice, a so-called family fund is also used. In broad terms, such a fund can be compared to the certification of assets.
Written by Stef Goossens, Tax Expertise Manager.
"}},{"accordionList":[{"richBody":{"value":"The information provided by ING in this article is not an offer, advice, or financial service and is intended solely to inform and provide practical tips. We recommend consulting a specialist for your financial and/or wealth planning. While this article has been compiled with the utmost care, inaccuracies or omissions may occur. ING is not liable for any damage (of any kind) resulting from the use of the information provided. No rights can be derived from this information. Any rates mentioned are indicative and not binding for ING. All rights and changes reserved. This is a publication of ING Bank N.V., registered in Amsterdam.
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