The Netherlands has announced a proposal to introduce a 36% tax on unrealized capital gains, potentially taking effect on January 1, 2028, pending Senate approval. The tax would apply to stocks, ETFs, savings accounts, and cryptocurrencies, meaning investors could be taxed annually on portfolio growth—even if they have not sold their assets.
Example Scenario
📈 Initial portfolio: €100,000
📈 Portfolio grows to: €140,000
📈 Unrealized gain: €40,000
📈 After €1,800 exemption: €38,200 taxable
📈 36% tax owed: €13,752
Importantly, if markets subsequently decline, taxes already paid would not be refunded. While losses may be carried forward to offset future gains, previously taxed unrealized gains would remain subject to the tax.
Three-Year Illustration
💼 Initial investment: €100,000
💼 Total tax paid: €13,752
💼 Portfolio value after market recovery: €110,000
💼 Net capital after tax: €96,248
Although the portfolio appears profitable on paper, the investor’s actual capital after taxes would fall below the original investments.
Potential Impact
This framework may increase the risk of forced asset sales, as investors could need to liquidate holdings to cover tax liabilities on gains that have not yet been realized.
