Not tax or legal advice. This page sorts public sources, as of 1 Nov 2026. Whether and how any of it applies to you is a question for your tax adviser.
In short
- The Netherlands is rebuilding its box 3 tax on savings and investments: instead of a notional return, the actual return would be taxed (Wet werkelijk rendement box 3, no. 36.748).
- The Tweede Kamer passed it on 12 Feb 2026. After its debate on 30 Jun 2026, the Eerste Kamer postponed its vote and is waiting for an amending bill. It is not law; until then the current box 3 system applies.
- The original bill would tax unrealised changes in value every year as well, with real estate and start-up shares only on sale. The amending bill would extend taxation on sale from 2028.
- Separately, this already applies today: if you leave with a stake of 5% or more, you get a protective assessment (conserverende aanslag) in box 2.
- Liechtenstein doesn't change Dutch rules. If you're considering a move, check box 2 and box 3 case by case.
Status check 1 Nov 2026
What's in the Dutch parliament?
Sorted, with sources. Box 3 covers savings and investments, box 2 substantial shareholdings in companies.
NLin parliament
Wet werkelijk rendement box 3
- The actual return would be taxed, under the bill including unrealised changes in value. Real estate and start-up shares only on sale (Eerste Kamer, Dutch).
- Tweede Kamer: passed on 12 Feb 2026.
- Eerste Kamer: plenary debate on 30 Jun 2026, vote postponed. On 13 Oct 2026 the committee decided to wait for the amending bill.
- Until a decision, the current box 3 system applies.
NLgovernment bill
Amending bill from 2028
- Cabinet letter on 29 Sep 2026, cabinet approval on 2 Oct 2026, since then with the Council of State for advice (Wetgevingskalender, Dutch).
- Aim: extend taxation on sale (vermogenswinstbelasting) from 2028.
- In the government's scenario letter this variant (scenario 4) means all financial instruments such as shares, bonds and options from 2028, other assets from 2030 (letter to parliament, 13 Sep 2026, Dutch). The exact scope depends on the text of the amending bill.
- Handling in the Tweede Kamer is pending.
NLlaw
Leaving with a stake: box 2
- If you leave with a stake of 5% or more, the tax is secured by a conserverende aanslag (Belastingdienst, Dutch).
- It falls due on a sale or a dividend, for example.
- For moves since 15 Sep 2015, there is no remission after 10 years any more.
As of 1 Nov 2026. New box 3: in parliament, not law. Box 2 on departure: law in force.
What it honestly means
On box 3 many already read "tax on paper gains from 2028". The status is more open. Three things matter:
- Nothing is fixed yet. The Eerste Kamer hasn't voted and the amending bill is with the Council of State. If you're making decisions now, plan with scenarios and get advice.
- Substance, not a mailbox. An address alone is neither a residence nor a company seat. If you build something in Liechtenstein, you need a real presence: a registered company with its seat and desks on the ground, a team, and decisions made here. More: Substance in Liechtenstein.
- Box 2 applies today. If you hold 5% or more of a company and leave, the protective assessment comes with you, without a time limit. Double taxation questions come on top: Double taxation and Liechtenstein.
Why we still like talking about Liechtenstein: the environment is predictable. Founders plan in years, not in headline cycles.
Exit taxes in Europe compared
Almost everywhere, what grew in the old country is taxed. A short comparison as of 1 Nov 2026. Every country including wealth and data taxes: Tax news Europe.
| Country | Status 1 Nov 2026 | Source |
|---|---|---|
| Italy | Government bill, not law. 26% on unrealised gains from €800,000 in financial assets, resident 6 of 10 years, planned from 1 Jan 2027. | Il Sole 24 Ore |
| Germany | Law in force. From a 1% stake in a corporation and 7 of 12 years fully taxable: the gain in the shares is taxed on moving away. Instalments over seven years on application. | § 6 AStG (German) |
| France | Law in force, change at first reading. From €800,000 in securities, resident 6 of 10 years. Today the tax lapses after 2 or 5 years; on 30 Oct 2026 the Assemblée nationale adopted 15 years at first reading. | Amendment I-462 (French) |
| Norway | Law in force. Moves since 20 Mar 2024: unrealised gains above NOK 3m, payable within 12 years. | Skatteetaten |
| Belgium | Law in force since 2026. Exit tax as part of the 10% capital gains tax. Automatic deferral for EU and EEA states among others; not owed without a sale within 2 years. For Liechtenstein, check case by case. | SPF Finances (French) |
| Netherlands | Law in force for box 2. Leaving with a stake of 5% or more triggers a protective assessment (conserverende aanslag). Box 3 is being rebuilt; that is still in parliament. | Belastingdienst (Dutch) |
| Spain | Law in force. From €4m in shares and holdings, or more than 25% of a company worth more than €1m, resident 10 of 15 years. For moves to an EU or EEA state with exchange of information, by election only due on a sale within 10 years. For Liechtenstein, check case by case. | Art. 95 bis LIRPF (Spanish) |
| Austria | Law in force. Moving away counts as a disposal of capital assets, special rate 27.5%. For moves to an EU/EEA state, on application assessed only on an actual sale. For Liechtenstein, check case by case. | § 27(6) EStG (German) |
| Denmark | Law in force. From DKK 100,000 in shares and usually after 7 years of tax liability, gains count as realised on departure. Interest-free deferral; security required outside the EU and the Nordic countries. For Liechtenstein, check case by case. | Skattestyrelsen (Danish) |
| United Kingdom | No general exit tax. If you return within 5 years, gains made while abroad can be taxed (temporary non-residence). | gov.uk HS278 |
| Ireland | No general exit tax. Return rule for domiciled individuals after no more than 5 years away (holdings of 5% or more, or over €500,000). | Revenue s. 29A |
| Switzerland | No general exit tax for individuals. According to the Federal Department of Finance, the Federal Council considers one ruled out under the constitution. | Federal Department of Finance (German) |
The basics: Exit tax.
Liechtenstein in numbers
| Item | Status | Source |
|---|---|---|
| Corporate income tax | 12.5%, since 2011 (Tax Act in force since 1 Jan 2011) | llv.li, gesetze.li SteG |
| Minimum corporate income tax | CHF 1,800 a year | llv.li |
| EEA | Member since 1995 | gesetze.li |
| Currency | Swiss franc (CHF) | – |
| Blockchain Act (TVTG) | in force since 2020 | gesetze.li |
| GmbH (LLC) | from CHF 10,000 share capital | GmbH fact sheet, llv.li |
| EU list of non-cooperative tax jurisdictions | Liechtenstein is not on it (update 9 Oct 2026) | Council of the EU |
It's not a hack. It's boringly predictable, and that's the point. How incorporation works: GmbH formation in Liechtenstein.
digihub · In der Specki 3, Schaan
Substance means a real place to work
If you're looking at Liechtenstein seriously, you need more than an address: an office, people on the ground, decisions made here. At digihub in Schaan you get real desks, not a mailbox: coworking with a Flex Desk from CHF 169, a Full Desk from CHF 299 or a Private Office from CHF 549 a month, plus meeting room and community. A business address is available by agreement (Registered office & business address).
Come by for a coffee, and we'll see together whether Liechtenstein even makes sense for you.
Read next
- Tax news Europe: all countries at a glance
- Italy exit tax: what the draft says
- France exit tax: 15 years at first reading
- Norway exit tax: the 12-year rule
- Belgium: 10% capital gains tax and exit tax
- UK: Founders' Relief and non-dom
- Spain: solidarity tax and exit tax
- Switzerland: JUSO initiative rejected, what applies now
- Austria: inheritance tax called for, exit tax applies
- Denmark: no wealth tax, inheritance duty proposed
- Ireland: 31% capital gains tax in Budget 2027
- Exit tax: the basics
- What does substance mean in Liechtenstein?
- GmbH formation in Liechtenstein
Sources
- Eerste Kamer: Wet werkelijk rendement box 3 (36.748, Dutch)
- Wetgevingskalender: amending bill extending vermogenswinstbelasting in box 3 (Dutch)
- Letter to parliament on box 3 (13 Sep 2026, Dutch)
- Belastingdienst: protective assessment on emigration (Dutch)
- llv.li: corporate income tax (German)
- Council of the EU: EU list of non-cooperative jurisdictions, update 9 Oct 2026
- llv.li: GmbH fact sheet (German)
Not tax or legal advice. Orientation based on public sources, as of 1 Nov 2026. The box 3 reform may still change in parliament. Please check your own case with a tax adviser or lawyer in the Netherlands and Liechtenstein.
Content from digihub.li · reviewed 1 November 2026.