On Oct. 20, we responded to a consultation from the Ministry of Finance on the actual return box 3 bill. DUFAS is pleased that there is a draft bill proposing a tax on the actual return for income and assets in box 3. It is important for savers and investors to be able to set aside their money to build up a good provision for later. A levy on actual returns should prevent taxation from being the guiding factor in wealth-building choices.
Hybrid system
The bill contains a hybrid system, with a capital gains tax, capital gains tax and a flat tax. We question this hybrid system because it may lead to undesirable behavioral effects. We believe that not tax treatment but the most appropriate form of wealth accumulation should be leading. In addition, we wonder whether the introduction of this hybrid system is not very complex, also for the Tax Administration. It must be prevented that the introduction from January 1, 2027 will come under pressure.
Loss settlement
Another point of interest is the possibility of loss relief. We believe that loss relief should be broadly available in both prior and subsequent years. Also, a loss relief threshold should be applied very narrowly, as such a threshold is detrimental to taxpayers with fluctuating income.
