Tax On Unrealized Gains

Today we are talking about a policy idea that keeps resurfacing around the world, taxing unrealized gains.

If you have ever underwritten a deal, you already know the difference between a gain on paper and cash in the bank. Unrealized gains are accounting gains. They exist because an asset is worth more today than it was yesterday, at least according to some valuation method. But until you sell the asset, refinance it, or otherwise monetize it, that gain is not cash flow. It is potential.

In the Netherlands, there is proposed legislation that would tax unrealized capital gains. It is being discussed under the umbrella of reforming “Box 3,” the part of the Dutch personal income tax system that applies to savings and investments. The Dutch lower house adopted a bill on February 12, 2026, often referred to as the Box 3 Actual Return Act, with an intended effective date of January 1, 2028, although the Finance Minister has already indicated amendments may be needed and that Senate approval is uncertain. 

So why is the Netherlands going down this road? Because their current system has been under pressure for years.

Historically, Box 3 taxed investors based on a deemed return, a fictitious assumed rate of return, rather than what someone actually earned. When interest rates were near zero, people with cash savings were taxed as if they were earning healthy investment returns. Courts rejected that approach, and the government has been trying to craft a replacement. In response, a bill was advanced to move from deemed returns to “actual return.” The catch is in how “actual return” is defined. 

Under the bill the system would tax actual annual returns at a flat rate, and that includes value increases that have not been realized through sale, in other words, unrealized gains. 

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