Collective ruling box-3 mass objection procedures 2017 to 2020

Collective ruling box-3 mass objection procedures 2017 to 2020

The Tax and Customs Administration has published the collective decision in the massive objection procedures against the box-3 tax for 2017 to 2020. All 200,000 objections have been declared well-founded. This does not mean that the participants in the mass appeal procedures now know how much they will get back and when.

There is also nothing known about possible compensation for other taxpayers who have paid too much box-3 levy. According to the cabinet, a box-3 levy based on the actual return cannot come into effect until 2025. However, urgent legislation is currently being worked on, which should provide a solution for the intervening years.

The emergency legislation makes adjustments to the existing box-3 legislation. The cabinet undertakes to send a memorandum of direction for the recovery operation to the House of Representatives before 1 April 2022. The left-wing opposition parties have already announced a private member’s bill that is based on a progressive levy on assets minus debts with a tax-free allowance of € 100,000 per person. The owner-occupied home remains in box 1 and substantial interest shares in box 2. The rate increases from 1% to 500,000 to 5% above € 5 million in taxable capital.

Tax assessments and tax return 2021

The ruling of the Supreme Court also has consequences for 2021 and later years. No final assessments are currently sent to taxpayers with box-3 capital. An exception is only made if there is a threat of prescription or if there is an interest in the taxpayer. As soon as it is clear what the recovery will look like, these attacks will be reinstated. Taxpayers will be informed about this.

The Tax and Customs Administration asks taxpayers to pay the provisional tax assessment 2022, pending further decisions. They are also asked to simply submit the 2021 tax return, stating the box-3 capital. Taxpayers with box-3 capital will probably receive their 2021 assessment later than 1 July 2022, even if they submitted their 2021 tax return before 8 April.


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Who are Suurmond Tax Consultants

Since 1986 accounting and corporate tax advice in relation to establishing a company or branch in The Netherlands is one of our many expertises we provide to our business clients.

In addition, we can also assist in a variety of other cross-border situations. We will ensure you are compliant as well as pay no more tax than needed. Examples include advising clients as to working abroad, taxation of pension and property tax, and amnesty ruling. We file all types of tax returns and specialise for example in the 30% ruling and 183-day rule consequences. The value we can add by offering our fiscal advice, is a key focus point to us. Also, what should not be overlooked, is the fact that a correct tax return will prevent future issues and penalties. This is essential when setting up business in a new country. 

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J.C. Suurmond & zn. Belastingadviseurs
Zwarte Zee 100
3144 DE Maassluis
T: +31 (0)10-3033701


General information

CoC register: 27224918
VAT: NL 8016.36.668.B.01
Tax consultant number: 330826


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