Exit tax for Dutch people leave the Netherlands

1. What "exit tax" means in Dutch practice and the assets it targets

Dutch exit taxation is focused on taxing unrealised capital gains and claims accrued while resident that the Netherlands could lose when a taxpayer leaves; in practice this commonly targets substantial shareholdings (typically applied where a taxpayer holds at least 5% of a company) and other international income and capital gains ^{[6] [1]}. The tax can take the form of a “preserving assessment” that secures the tax administration’s claim on future income that arose while resident, notably used against directors and major shareholders to capture box‑2 style gains ^[3].

2. How the claim is enforced and practical payment rules

When the Netherlands issues a preserving assessment it effectively treats the unrealised gain as taxable, but payment mechanics recognise the taxpayer often has no liquid income upon leaving: relocation within the EU generally triggers an automatic, unconditional and interest‑free deferral of payment, while other situations may require a bank guarantee if payment is deferred, particularly on business transfers or company relocations ^{[3] [4]}. For businesses closing or moving, taxpayers may choose immediate settlement or deferment subject to providing security to the Tax and Customs Administration ^[4].

3. Proposed changes on the table and the five‑year claim idea

Recent reporting and government documents show legislators and ministries are exploring a broader exit regime that could extend the Dutch tax claim on international income and capital gains for up to five years after departure, aimed at preventing wealthy emigrants from avoiding tax by moving to low‑tax jurisdictions such as Dubai ^{[1] [2]}. These proposals are part of wider 2026 tax planning and EU coordination efforts and are still being fleshed out; implementation and exact scope remain subject to legislative choice and international law constraints ^{[7] [2]}.

4. Legal and EU constraints that limit how far the Netherlands can go

Any Dutch exit tax must respect EU law and international treaties: past case law and EU considerations mean the timing of emigration and residence rules affect enforceability, and the government is explicitly comparing models used in other European countries while mindful of European Court of Justice precedents ^[2]. That legal context also explains why deferral within the EU is routinely granted and why policymakers are cautious about sweeping extraterritorial grabs without harmonised international backing ^{[3] [2]}.

5. Who is most exposed and the political debate

The chief targets are high‑net‑worth individuals with substantial interests and entrepreneurs who benefited from Dutch public goods, a contention advanced by motions in parliament urging the government to act ^{[5] [2]}. Critics warn of unintended consequences: commentators and MPs argue HNW Dutch citizens could relocate to other EU states or outside the Netherlands before stricter rules take effect, potentially undermining competitiveness ^[5]. The government’s 2026 Tax Plan and related policy papers show a balancing act between raising revenues and maintaining the investment climate ^{[7] [8]}.

6. What remains unsettled and practical takeaways

Key uncertainties include final legislative scope, exact thresholds, how long the post‑departure claim would apply in practice, and interactions with bilateral treaties and EU case law—documents show the Netherlands is still elaborating implementation details and coordinating with EU/OECD workstreams ^{[2] [7]}. Practically, emigrants with company shares or complex asset mixes should expect preserving assessments, possible deferral mechanisms or guarantees, and ongoing political movement rather than a fully crystallised new tax yet ^{[3] [4] [1]}.