The inside track: The Netherlands has simply moved to tax Bitcoin like a inventory, marked to market. Lawmakers within the Dutch Home backed a Field 3 overhaul that may tax “precise returns,” together with annual worth adjustments in liquid property like BTC, at a flat 36%, even when you by no means promote. The plan targets Jan. 1, 2028 (pending Senate approval), turning Bitcoin’s volatility right into a yearly cash-flow drawback.
The Dutch Home of Representatives has authorised a serious overhaul of the Netherlands’ Field 3 regime that may tax “precise returns” on financial savings and investments, together with the annual change in worth of liquid property comparable to Bitcoin, at a flat 36% price.
With a focused begin date of Jan. 1, 2028, pending Senate approval, the proposal alerts a basic shift in how European governments could deal with digital property: shifting from taxing the act of promoting to taxing the act of holding.
Whereas it’s simple to summarize this legislative transfer as a “36% unrealized positive factors tax,” a extra revealing framing is that the Netherlands is in search of to shift from a court-contested deemed-return system to at least one that treats many monetary property as in the event that they had been marked-to-market annually.
That shift doesn’t simply change what’s taxed. It adjustments when Bitcoin holders really feel the tax system, as a result of BTC’s infamous volatility successfully turns into a cash-flow drawback for native buyers.
How Field 3 works immediately, and why it already creates a carry price
Field 3 is the Netherlands’ bucket for taxing returns on property, protecting financial savings, investments, second properties, and extra.
Presently, a lot of Field 3 is calculated utilizing assumed returns and a flat tax price. This technique signifies that even a flat or down yr can nonetheless include a invoice.
The Dutch tax authority’s 2026 steering signifies a 36% Field 3 tax price and an assumed return of 6.00% for “investments and different property,” a class that features objects comparable to shares and bonds (and, in apply, many non-cash holdings).
That alone can create a significant carry price. A easy illustration clarifies the burden: if €100,000 of Bitcoin sits within the “investments and different property” bucket on the margin, an assumed 6.00% return implies €6,000 of taxable return.
At 36%, the invoice is €2,160, or about 2.16% of the place per yr earlier than thresholds and offsets.
The 2028 proposal flips this logic completely. As an alternative of “we’ll assume you earned X,” the taxable return is supposed to mirror what an investor really earned.
However for many liquid monetary property, the structure is “capital progress” taxation (capturing revenue and the annual change in worth) relatively than ready till a sale.
For Bitcoin, that successfully means paying tax on unrealized positive factors even when you by no means offered a Satoshi.
The plan contains mitigations designed to blunt the sharpest edges. Reporting across the reform highlights a €1,800 tax-free annual return threshold and an indefinite loss carryforward, although solely losses above €500 are eligible.
These options assist, however they don’t remove the core behavioral shift: giant holders would nonetheless want liquidity even in robust Bitcoin years.
Why Bitcoin holders will really feel it in a different way
Underneath a mark-to-market-like method, Bitcoin’s most celebrated function (large, discontinuous upside) is precisely what creates friction.
If Bitcoin rises 60% in a yr, the taxable “return” on a €100,000 beginning place is €60,000. At 36%, the tax is €21,600.
That’s not “36% of your stack,” however it might probably nonetheless translate into promoting a noticeable slice of holdings (or borrowing in opposition to them) to pay the invoice.
The impression of this coverage is magnified by the truth that Dutch buyers are already deeply built-in into the crypto market, which means this isn’t a distinct segment tax on a number of hobbyists.
The Netherlands has measurable publicity to crypto by way of regulated merchandise. The Dutch central financial institution reported that on the finish of October 2025, households held €182 million in crypto ETFs and €213 million in crypto ETNs.
Moreover, pension funds held €287 million in “crypto treasury shares,” with whole oblique crypto securities holdings exceeding €1 billion.
This substantial footprint suggests {that a} shift to annual taxation may drive a migration in how these property are held.
If compliance turns into annual and valuation-based, broker-held ETP publicity may be simpler to manage than self-custody.
This aligns with a world pattern famous in Fineqia’s January 2026 report, which put international digital-asset ETP property underneath administration at $155.8 billion on the finish of the month.
These autos have proven they will stay “sticky” even because the broader crypto market cap falls, however the brand new tax regime may take a look at that resilience.
Netherlands’ transfer dangers spreading a Bitcoin contagion
The potential for contagion has drawn sharp criticism from business heavyweights.
Rickey Gevers, a cybersecurity skilled, warned that these mechanics are genuinely high-risk to market stability.
In keeping with him:
“The tax on unrealized positive factors could cause a financial institution run if buyers panic. If everybody begins promoting on one particular date to safe money to pay the tax, the value will crash like loopy. That crash itself can then set off much more panic, inflicting much more buyers to promote. Everybody sees the worth of their portfolio dropping, whereas on the identical time figuring out that the quantity of tax they must pay is not going to go down.”
On the identical time, Balaji Srinivasan, Coinbase’s former CTO, argued that the impression of those taxations shouldn’t be restricted to native markets. He introduced the thought as a contagion threat, the place pressured liquidation stress spills into worth formation.
He wrote:
“It’s not simply that you just don’t need to maintain property as a Dutchman. You additionally don’t desire a Dutchman to carry your property.”
Srinivasan outlined a hypothetical liquidity spiral as an example the chance.
He described a state of affairs by which an asset has a complete market cap of $10,000, with 10 shares held by 10 completely different Dutch holders, every paying close to zero. If the share worth hits $1,000 on tax day, every holder faces a 36% tax legal responsibility of $360.
The crypto entrepreneur defined:
“The primary man sells his one share, will get $1,000, and pays $360 in tax whereas retaining $640. However the first man’s sale reduces the market worth to $960 per share. So when the second man sells, he solely retains $600 after paying $360 in tax.”
By the point the seventh holder sells, the value may collapse to $200 per share, an inexpensive state of affairs if 60% of the cap desk is dumped.
At that worth, the seventh holder should promote their total place for $200 and nonetheless owe $160 in taxes.
He added:
“The eighth, ninth, and tenth guys are much more screwed. By the point they promote, the value will seemingly have crashed to $100 per share or much less. As with the seventh man, even 100% liquidation is not going to cowl their tax burden.”
Srinivasan, who expressed sympathy for what he termed the “previously Flying Dutchmen, now Crying Dutchmen,” advised this dynamic may drive buyers to dam residents of wealth-taxing jurisdictions from cap tables to keep away from liquidation contagion.
The exit tax and European contagion
An annualized method to taxing worth strikes will increase the worth of one other coverage software, exit taxes.
If taxpayers can cut back future legal responsibility by shifting earlier than the beginning of a taxable interval, governments usually reply by tightening the principles on departure.
Within the Netherlands, the exit-tax dialog is not summary. A Dutch authorities letter following parliamentary debate on taxation of the extraordinarily rich explicitly references motions calling for an EU-level exit tax and for growing nationwide exit-tax choices.
Individually, the Dutch tax authority notes it could difficulty a “protecting evaluation” in sure emigration conditions, illustrating that defending the declare when somebody leaves is already a well-recognized idea within the system.
That is a part of a wider European pattern. Germany expanded components of exit taxation to sure funding fund holdings from Jan. 1, 2025, doubtlessly taxing beforehand unrealized “hidden reserves” when people relocate.
France already has an exit tax that applies to qualifying unrealized positive factors when leaving the nation.
Alex Recouso, the founding father of CitizenX, argues that this sample is predictable by noting that:
“It all the time begins with an unrealized positive factors tax. Then, an exit tax. Lastly, it is international taxation.”
Recouso pointed to France’s proposal within the 2026 Nationwide Funds to undertake citizenship-based taxation, underneath which residents would pay tax on international revenue in the event that they transfer to a area with a tax price 40% decrease than France’s.
He additionally highlighted the UK’s challenges, noting that after a capital positive factors tax improve, the nation misplaced greater than 15,000 high-net-worth people in 2025, leading to a ten% decline in internet capital positive factors tax income.
From taxation to confiscation?
The Netherlands’ transfer lands as EU enforcement capability is rising.
DAC8 (the EU’s newest replace to administrative cooperation) expands automated change of data to crypto-asset transactions, with guidelines getting into into drive on Jan. 1, 2026.
This infrastructure makes annualized crypto taxation possible by making certain dependable information flows from service suppliers.
Nonetheless, critics view these developments as an existential menace to property rights.
Recouso framed the state of affairs as a transition “from taxation to confiscation,” warning that EU nations are elevating taxes and blocking exits as a result of they’re successfully bankrupt.
“Ultimately, they are going to attempt to seize your property,” Recouso mentioned, evaluating the state of affairs to the US seizure of gold underneath Govt Order 6102.
He added:
“The best to exit is a basic human proper. Simply have a look at the historical past: all of the worst states have revoked the human proper to exit.”
In mild of this, Recouso suggested holding Bitcoin in self-custody and acquiring second passports from pleasant jurisdictions like El Salvador, echoing Ray Dalio’s sentiment that “location is as vital as your allocation.”
So, if the Netherlands’ 2028 plan turns into regulation, will probably be one of many clearest examples in Europe of Bitcoin shifting from a “sell-event tax story” to a “hold-event tax story.”