What this choice actually costs you
The same portfolio, two very different rulebooks
Take Jeroen, 41, with €100,000 in savings earning 1.5%, €150,000 in ETFs that returned 6% this year, and a €10,000 investment loan at 4%. Under the 2026 rules the Belastingdienst ignores all of that and applies its own numbers: 1.28% on his savings (€1,280), 6.00% on his investments (€9,000), minus 2.70% on his debt (−€270). Deemed return: €10,010. After the wealth exemption of €59,357 his taxable share works out to roughly €7,530, and the bill at 36% is about €2,712.
Under the 2028 rules the fiction disappears. Jeroen's actual return, €1,500 interest plus €9,000 investment gain minus €400 loan interest: is €10,100. Subtract the new €1,800 tax-free return and he pays 36% of €8,300: €2,988.
In this average year the two systems land within €300 of each other. That is by design. The forfait percentages are calibrated to long-run averages. The gap appears the moment your year is not average.
Where the pain moves: lean years vs boom years
Keep Jeroen's portfolio fixed and only change how the markets behave. In a lean year his real return is €2,000. The 2026 system does not care: still €2,712, unless he files rebuttal evidence. The 2028 system charges 36% of (€2,000 − €1,800), €72.
Now a boom year: €25,000 of real gains, most of it unsold paper profit on his ETFs. The 2026 bill is unchanged at €2,712 because the forfait caps out at 6.00%. The 2028 bill is 36% of €23,200, €8,352: payable in cash even though he sold nothing.
That is the trade in one picture. The 2028 system removes the injustice at the bottom and sends the bill to the top. If your portfolio is volatile, expect your Box 3 tax to become volatile with it, and plan liquidity for the years your screen is green.
Why 88% of your 2026 bill comes from the investment forfait
Look inside Jeroen's €10,280 of positive deemed return: €1,280 comes from €100,000 of savings, €9,000 from €150,000 of investments. Investments are 60% of his assets but drive 88% of the taxed return, because the 6.00% forfait is nearly five times the 1.28% savings rate.
This is why the current system quietly punishes anyone the Belastingdienst classifies as an 'investor': including holders of a second home or crypto that went nowhere. It is also why the Hoge Raad intervened twice: the 2021 Kerstarrest ruled that taxing fictional returns breaches the European Convention's property protections, and the June 2024 ruling forced the rebuttal scheme that now lets you prove a lower real return for 2025-2027.
Until 2028 arrives, the practical move is simple: check every year whether your real return is below the deemed one. If it is, the tegenbewijsregeling exists precisely for you: use the opgaaf werkelijk rendement form and pay tax on reality instead of fiction.