The tax leak is related to the way interest on bonds is included in the calculations of the actual yield in the rebuttal scheme. When purchasing a bond, the purchase price includes a portion of the already accrued interest. However, when calculating the value of the bond at the end or beginning of the year, the value without the purchased interest is considered. This difference in calculations means that someone can show a loss in the first year. The following year, there may be a relatively high profit in applying the rebuttal scheme, but a taxpayer can choose to apply the deemed yield that year. This deemed yield then forms the upper limit for taxation, regardless of how high the actual yield is that year. This creates an unwanted tax leak.
Solution
In box 3, there is currently an exemption for short-term periods, such as current interest periods from a bank account, a savings account, or a bond. A right to receive interest on, for example, February 1 already has a certain value on the reference date of January 1. Due to the exemption for short-term periods, this value is not taken into account on January 1. To close the leak, the cabinet wants to no longer apply the exemption for short-term periods in the rebuttal scheme for box 3. The accrued interest from bonds will no longer be exempt. Only for bank deposits will the exemption for short-term periods continue to apply, as this does not provide tax avoidance opportunities for bank deposits.
Additionally, the rule for the rebuttal scheme that states that bonds and other securities with short-term periods are valued at the closing quotation on the last trading day of the calendar year will also be removed. This quotation is exclusive of accrued interest. By removing this rule, bonds must be valued at their fair market value.
The adjustments to close the leak only apply to the rebuttal scheme and not to the determination of the deemed yield in box 3, as this leak does not occur there.
Effective date
The proposed legislative amendment will be included in the Tax Plan 2026. This legislative proposal will be submitted to the House of Representatives on Princes Day. The measures will take effect in 2026, retroactively from August 25, 2025, at 16:00. For assets that are already part of a taxpayers box 3 assets at that time, the old system will continue to apply.
