30% Ruling Impact on Box 2 and Box 3

Key Takeaways

The 30% ruling itself only affects Box 1 (your salary). But the associated partial non-resident status could dramatically reduce your Box 2 and Box 3 tax.
Important: Partial non-resident status was repealed as of January 1, 2025. Only those who were already using it before 2024 can continue through 2026 under transitional rules.
With partial non-resident status (if eligible), foreign investments and savings are exempt from Box 3 tax. Foreign substantial interests are exempt from Box 2 tax.
From 2027 onward, partial non-resident status will no longer be available to anyone.
Understanding these rules remains important for those still under transitional protection, and for understanding your post-ruling tax position.

How the 30% Ruling Interacts With the Box System

The Dutch tax system has three boxes:

Box	What It Covers	30% Ruling Direct Effect	Partial Non-Resident Effect
Box 1	Salary, business profit, home ownership	30/20/10% of salary is tax-free	No additional effect
Box 2	Substantial interests (5%+ company shares)	No direct effect	Foreign substantial interests are exempt
Box 3	Savings, investments, other assets	No direct effect	Foreign assets are exempt

The 30% ruling directly reduces only your Box 1 tax. The Box 2 and Box 3 benefits come exclusively through electing partial non-resident taxpayer status, which is a separate choice available to 30% ruling holders.

Box 3: Savings and Investments

How Box 3 Normally Works

As a Dutch resident, Box 3 taxes your net assets (assets minus debts) above the tax-free threshold:

Component	2026 Value
Tax-free threshold (per person)	€59,357
Tax-free threshold (tax partners)	€118,714
Tax rate	36% on deemed return

The deemed return is a fictional percentage of return the government assumes you earn, regardless of actual returns. It varies by asset category:

Asset Category	Deemed Return (2026)
Savings (bank deposits)	1.28%
Other investments (stocks, bonds, crypto, property)	6.00%
Debts	2.70% (deductible)

Box 3 With Partial Non-Resident Status

When you elect partial non-resident status, Box 3 changes fundamentally:

Included (taxable):

Dutch real estate (not your primary residence — that is Box 1)
Dutch bank accounts and investments (at Dutch institutions)

Excluded (exempt):

Foreign bank accounts
Foreign stock portfolios and investment accounts
Foreign real estate
Foreign bonds, crypto held on foreign platforms
Any other asset located outside the Netherlands

Good to know

The definition of "foreign" is based on where the asset is held or located, not where the underlying investment is domiciled. A US stock held through a Dutch broker (like DeGiro) is a Dutch asset. The same US stock held through a US broker (like Schwab) is a foreign asset. The location of the financial institution matters.

Worked Example: Box 3 Comparison

Situation: You have the following assets:

€80,000 in a Dutch bank account (ING)
€200,000 in a US brokerage account (stocks and bonds)
€100,000 in a UK savings account
€150,000 apartment in Spain (rented out)

Asset	Normal Resident	Partial Non-Resident
Dutch bank account (ING)	Included	Included
US brokerage account	Included	Exempt
UK savings account	Included	Exempt
Spanish apartment	Included	Exempt
Total Box 3 base	€530,000	€80,000
Tax-free threshold	−€59,357	None (non-resident for Box 3)
Taxable base	€473,000	€80,000
Approximate annual tax	~€7,200	~€300
Annual saving		~€6,900

Warning

Note that as a partial non-resident, you lose the €59,357 tax-free threshold for Box 3. This only matters if your Dutch assets are significant. In the example above, the €80,000 Dutch bank account is fully taxed (no threshold), but the saving from exempting €450,000 in foreign assets far outweighs the loss of the threshold.

Box 2: Substantial Interests

What Is a Substantial Interest?

A substantial interest (aanmerkelijk belang) exists when you own 5% or more of a company's shares (or certain rights equivalent to shares). Box 2 taxes:

Dividends from the company
Capital gains when you sell the shares

Box 2 Tax Rates (2026)

Income from Substantial Interest	Tax Rate
Up to €68,843	24.5%
Above €68,843	31%

Box 2 With Partial Non-Resident Status

With partial non-resident status:

Dutch substantial interests (companies established in the Netherlands) → taxed normally in Box 2
Foreign substantial interests (companies established abroad) → exempt from Box 2

Worked Example: Box 2 Comparison

Situation: You own 20% of a software company registered in India. The company pays you €50,000 in dividends this year.

	Normal Resident	Partial Non-Resident
Dividend income	€50,000	€50,000
Box 2 taxable	€50,000	€0 (foreign company, exempt)
Tax	€12,250 (24.5%)	€0
Saving		€12,250

This is an enormous benefit for expats who own shares in companies in their home country.

Tip

If you own shares in a company through a Dutch BV (holding structure), those shares in the BV are a Dutch substantial interest — not foreign, even if the BV owns foreign companies. The location of the direct shareholding entity matters for the partial non-resident classification.

Strategic Considerations

Where to Hold Your Investments

The distinction between Dutch and foreign brokers is critical:

Broker	Location	Partial Non-Resident Effect
DeGiro	Netherlands	Assets are Dutch → taxed
Interactive Brokers (Ireland)	Ireland	Assets are foreign → exempt
Schwab (US)	United States	Assets are foreign → exempt
Binck/Saxo (Netherlands)	Netherlands	Assets are Dutch → taxed
Your home country's bank	Foreign	Assets are foreign → exempt

Warning

Do not move assets between brokers solely for tax purposes without considering the full picture. Transaction costs, currency risk, account maintenance fees, and the temporary nature of the 30% ruling (it expires after 5 years) all matter. Moving assets to a foreign broker saves Box 3 tax while the ruling is active but has no benefit after it expires.

Timing of Investment Decisions

Box 3 is assessed on January 1 of each year. Your asset position on January 1 determines your Box 3 tax for the entire year. This means:

Assets held on January 1 at a foreign broker → exempt for the full year (with partial non-resident status)
Assets moved from a foreign to a Dutch broker before January 1 → taxed for the full year

If you are considering transferring assets, the timing relative to January 1 matters.

Stock Options and RSUs

Stock options and RSUs (Restricted Stock Units) from your employer are taxed in Box 1 when they vest or are exercised — not in Box 2 or Box 3. Partial non-resident status does not affect this.

However, once you hold the shares after vesting (and they are unrestricted), they become Box 3 assets. If you hold them at a foreign broker, they are exempt under partial non-resident status.

The Transition When the Ruling Expires

When your 30% ruling expires, you lose the ability to elect partial non-resident status. The impact:

Box 3 Transition

Before expiry: Foreign assets exempt from Box 3
After expiry: All worldwide assets included in Box 3

If you have €500,000 in foreign assets, your Box 3 tax could jump from €0 to approximately €7,000–€10,000 per year overnight.

Box 2 Transition

Before expiry: Foreign substantial interests exempt from Box 2
After expiry: All worldwide substantial interests taxed in Box 2

If you own shares in a foreign company, dividends and capital gains become taxable again.

How to Prepare

Calculate your post-ruling Box 3 tax — Know the number before the ruling expires so there are no surprises
Consider restructuring assets — Some expats consolidate investments into tax-efficient structures before the ruling ends
Build a tax reserve — Set aside money during the ruling period to cover the increased tax after it expires
Review your tax partner situation — With a tax partner, you have double the Box 3 threshold, which helps after the ruling ends
Consider whether to stay in the Netherlands — For some expats, the end of the ruling triggers a serious evaluation of whether the Netherlands remains financially optimal