Reference date arbitrage: temporarily moving assets in Box 3
"},"icon":{"transformBaseUrl":"https://assets.ing.com/transform/93160bf2-e0a9-463b-a803-c9bed727257d/Transactions-Transfer_Out_Euro_Outline","type":"image","width":32,"altTextNL":"\"\"","original":"https://assets.ing.com/m/36a20623fa4c307f/original/Transactions-Transfer_Out_Euro_Outline.svg","extension":"svg"},"paragraphs":[{"componentType":"paragraph","richBody":{"value":"Towards year-end, you might consider restructuring your Box 3 assets. For example, you could temporarily convert your other assets (such as investments) into savings. Another strategy is to take out a loan—possibly from your own private company—and deposit the funds into a savings account. The deductible fictitious return on debts is higher than the return on bank deposits, which lowers your Box 3 tax burden.
Asset type | Fictitious return 2025 | Fictitious return 2026 |
|---|---|---|
Savings | 1.44% (provisional) | 1.28% |
Other assets | 5.88% | 6.0% |
Debts | 2.62% (provisional) | 2.70% |
The conversion of ‘other assets’ into savings will be disregarded for tax purposes if you sell investments as of October 1 but (partially) repurchase them within three months in the new year.
The same rule applies to debts: if you take out a loan from October 1 onward and (partially) repay it within three months in the new year, the Dutch Tax Authority may disregard the debt for tax purposes in Box 3. If the (temporary) loan is with, for example, your own private company (BV), it’s important to also consider the impact of the Excessive Borrowing Act (Wet Excessief Lenen). If the loan from your BV exceeds € 500,000 as of December 31st, you may be subject to Box 2 taxation on the excess amount.
If you wait more than three months before buying back investments or repaying the loan, the shift is generally accepted.
"}},{"componentType":"paragraph","title":"Business motives make the difference","richBody":{"value":"If you can demonstrate that these asset shifts were driven by genuine business reasons – such as market trends or liquidity needs – the Tax Authority may accept them. It is important to be prepared to justify your actions if asked by the Tax Authority. Consult your tax advisor in a timely manner.
"}}]},{"title":{"value":"Box arbitrage: moving assets to another tax box
"},"icon":{"transformBaseUrl":"https://assets.ing.com/transform/0174d1a0-d34c-43a3-9a78-eea1cec03d39/Functionalities-Swap_Outline","type":"image","width":32,"altTextNL":"\"\"","original":"https://assets.ing.com/m/7f618a798a13fa0d/original/Functionalities-Swap_Outline.svg","extension":"svg"},"paragraphs":[{"componentType":"paragraph","richBody":{"value":"You can also temporarily move assets to another tax box (box 1or box 2) around the reference date, known as ‘box-hopping’. This might look attractive, but the law sets clear limits.
"}},{"componentType":"paragraph","title":"Within three months","richBody":{"value":"If you move assets to another box and back within three months around the Box 3 reference date, the amount counts in both boxes. You may even pay double tax and you cannot challenge this, even with business motives.
"}},{"componentType":"paragraph","title":"Between three and six months","richBody":{"value":"If you move your assets to another box for a period of three to six months around the Box 3 reference date and then move them back, double taxation may still apply unless you can prove that your actions were driven by genuine business considerations. Consult your tax advisor in a timely manner.
"}}]}]},{"componentType":"sectionTitle","title":"Counter-evidence rule: tax on actual returns"},{"componentType":"paragraph","richBody":{"value":"Since 2025, you can use the counter-evidence rule (Wet Tegenbewijsregeling) to show that your actual return is lower than the fictitious return (after adjustments for arbitrage). Your Box 3 tax will then be based on your actual return, calculated over your entire Box 3 assets.
"},"textLinks":[{"url":"/en/private-banking/knowledge-and-insights/wealth-growth/law-counter-evidence-scheme-box-3","text":"Read more"}]},{"componentType":"sectionTitle","title":"Make informed choices"},{"componentType":"paragraph","richBody":{"value":"Thinking about restructuring your assets around the reference date? Make sure your decisions are well-founded, aligned with your wealth plan, and – if temporary – driven by genuine business motives. This way, you avoid surprises and stay in control of your tax position.
This article was written by Stef Goossens and Robert Mantel, Tax expertise managers.
"}},{"componentType":"accordion","accordionList":[{"title":"Based on the situation as of December 1, 2025","richBody":{"value":"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 or tax advisor 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.
"}}]},{"componentType":"sectionTitle","title":"Read more"},{"componentType":"cards","cards":[{"componentType":"articleCard","cardType":"article","cardSize":"medium","title":"Law counter-evidence scheme in Box 3","body":"Could you be entitled for a refund? Read what the scheme entails and what it means for you.","image":{"transformBaseUrl":"https://assets.ing.com/transform/55688c83-fd74-434a-a0a3-ece1c3ad427c/Large_Web-and-Screen-Mid-adult-businessman-looking-at-some-documents-in-an-office-Exclusive-usage-for-ING-Private-Banking","type":"image","width":1920,"original":"https://assets.ing.com/m/4fdac08a2e7dc336/original/Large_Web-and-Screen-Mid-adult-businessman-looking-at-some-documents-in-an-office-Exclusive-usage-for-ING-Private-Banking.jpg","extension":"jpg"},"date":"2025-07-09","link":{"url":"/en/private-banking/knowledge-and-insights/wealth-growth/law-counter-evidence-scheme-box-3"}},{"componentType":"articleCard","cardType":"article","cardSize":"medium","title":"Box 3 assets in 2026: what will change?","body":"In 2026, Box 3 assets will continue to be taxed based on a fictitious return. Learn more.","image":{"transformBaseUrl":"https://assets.ing.com/transform/3d11d035-4bc9-4255-bcbe-f386e9689c34/A-young-woman-eats-from-a-bowl-and-sits-at-a-table-with-her-laptop-at-home","type":"image","width":5616,"original":"https://assets.ing.com/m/7ee5a3e4873289ce/original/A-young-woman-eats-from-a-bowl-and-sits-at-a-table-with-her-laptop-at-home.jpg","extension":"jpg"},"date":"2025-09-19","link":{"url":"/en/private-banking/knowledge-and-insights/prinsjesdag-2025/box-3-2026-fictitious-returns"}}]}]},"complementaryZone":{"flexComponents":[{"componentType":"cards","cards":[{"componentType":"productCard","cardType":"product","cardSize":"small","title":"Make an appointment","intro":"Let's start a conversation.","image":{"transformBaseUrl":"https://assets.ing.com/transform/3e538078-976f-4b74-b49c-90d7cd895df2/Web-12","type":"image","width":307,"original":"https://assets.ing.com/m/1d41bac33a10b194/original/Web-12.svg","extension":"svg"},"link":{"url":"/en/private-banking/customer-service"}},{"componentType":"productCard","cardType":"product","cardSize":"small","title":"Log in to My ING","intro":"Quick insights into your financial situation","image":{"transformBaseUrl":"https://assets.ing.com/transform/33c4e3a2-7e3d-47a1-9c6f-1993eedcdb8c/Web-13","type":"image","width":307,"original":"https://assets.ing.com/m/5aecfb619a645cd6/original/Web-13.svg","extension":"svg"},"link":{"url":"https://mijn.ing.nl/login"}}]}]}}}