Taxes & rules

Family loan in box 3: what value should you report?

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Family loan in box 3 with a worked example showing 300,000 euros outstanding principal and a current value of 319,701 euros

If you lend money to a child, parent or another person you know, you will often enter the outstanding loan balance in box 3 of your Dutch income tax return. That is straightforward, but it is not always the statutory basis for tax purposes. A long-term fixed-rate loan may have a current value that is higher or lower than its principal.

A Belastingdienst Knowledge Group position published on 22 May 2026 clarifies how that value should be determined. At the same time, it offers a temporary practical alternative: subject to certain conditions, taxpayers may continue to use the nominal value. What does this mean for your tax return, and what records should you keep?

Short answer

Under Dutch law, a family loan in box 3 must be valued at its fair market value (waarde in het economische verkeer) on the valuation date, or peildatum, of 1 January. For a loan that is repayable on demand, this value will usually be close to the outstanding balance. For a long-term fixed-rate loan, the current value may differ because, for example, the agreed interest rate has become higher or lower than the prevailing market rate.

According to the Knowledge Group position, the Belastingdienst also temporarily accepts the nominal value, provided you follow a consistent approach over time, described in Dutch as a bestendige gedragslijn. You cannot switch opportunistically between nominal and current value each year simply to obtain the lowest tax charge. Record the method you choose and the basis for that choice.

What changed in May 2026?

The main rule itself is not new. Article 5.19 of the Wet inkomstenbelasting 2001 (Income Tax Act 2001) already requires assets and debts in box 3 to be reported at fair market value.

The new position, KG:202:2026:7, explains how that rule applies to receivables repayable on demand, non-immediately repayable fixed-rate receivables, fixed-term debts without penalty-free early repayment, solvency and non-transferability.

It is therefore not a new box 3 law. It is an interpretation of the existing valuation rule, together with a practical approach that the Belastingdienst will accept for the time being.

Where does a family loan go on the tax return?

You must first determine which tax box applies to the loan for each party. The lender and borrower do not automatically receive the same tax treatment.

For the lender

For the person who lent the money, the loan will usually be a receivable, or vordering, in box 3. The Belastingdienst classifies receivables as "investments and other assets" (beleggingen en andere bezittingen). For 2026, the deemed return percentage for this category has been set at 6.00%.

According to the Belastingdienst's explanatory guidance, claims against your tax partner (fiscale partner) or minor children do not, for example, have to be reported as other receivables. A business loan may also be treated differently. Determine the correct tax box first, and only then apply the valuation rules.

For the borrower

For the borrower, the same family loan may be a debt in box 3. The provisional deemed return percentage for debts in 2026 is 2.70%. Only the part of a person's total debts above the debt threshold of 3,800 euros per person is taken into account.

If the loan qualifies as an owner-occupied home debt (eigenwoningschuld), it may instead fall in box 1 and the interest may be deductible. The lender will generally still hold a box 3 receivable. See also when interest on a family mortgage can be deducted.

Nominal value and current value are not the same

The nominal value is the amount that remains contractually repayable.

The fair market value is the amount that would be assigned to the receivable or debt between independent parties on the valuation date following a properly prepared sale. For a conventional loan with fixed payments, this current or present value is often estimated by discounting the future interest and principal payments at the market interest rate prevailing at that time.

An interest-rate difference can therefore create value:

• If the contractual interest rate is higher than the current market rate, the future interest payments are more attractive and the receivable may be worth more than the principal.

• If the contractual interest rate is lower than the current market rate, the receivable may be worth less than the principal.

• If the loan is repayable on demand or has a very short remaining term, its current value will usually be close to its nominal value.

A rate that was market-conform when the loan was agreed does not guarantee that its current value will still equal the principal several years later. For more background, see Market-conform interest: what rate can you charge family?.

The official worked example: 300,000 euros becomes 319,701 euros

The Knowledge Group position includes an example that clearly shows why the valuation can matter.

Taxpayer A borrows 300,000 euros from taxpayer B to finance a second home. For A, the amount is a debt in box 3. For B, it is a receivable in box 3. The loan is interest-only for twenty years and was agreed on strictly arm's-length terms. The fixed interest rate of 4.5% is paid annually in arrears. B cannot call in the receivable early, and A has no right to repay early without a penalty.

At the beginning of the second year, the market rate for a comparable loan has fallen to 4.0%, with nineteen years of the term remaining. Because the contractual rate is higher, the future payments are worth more. In the official example, their present value is 319,701 euros.

Outstanding principal: 300,000 euros

Current value in the official example: 319,701 euros

Difference: 19,701 euros

This difference does not mean that the borrower must suddenly repay 319,701 euros. The contractual principal remains 300,000 euros. The figure of 319,701 euros is solely the calculated tax value of the future cash flows on the valuation date.

If only the interest-rate difference is valued and both parties use the same contractual terms, the debt in this example will, in principle, have the same current value as the receivable. This is not a general requirement that both values must always be identical. Other factors may affect each side differently.

How large can the box 3 effect be in 2026?

For investments and other assets, the Belastingdienst applies a 6.00% deemed return in 2026. The box 3 tax rate is 36%. Compared with the nominal value, the current value from the example therefore produces 1,182.06 euros of additional deemed return:

19,701 euros valuation difference x 6.00% = 1,182.06 euros additional deemed return.

At a tax rate of 36%, this represents a maximum of approximately 425.54 euros in additional tax. This is an isolated indication only. The actual effect depends on factors including your total assets, the tax-free allowance of 59,357 euros per person, the allocation between tax partners and the composition of your assets.

For the borrower, a higher box 3 debt may instead reduce the calculation. Debts have a different deemed return percentage in 2026, however, and the debt threshold applies. If the loan is an owner-occupied home debt in box 1, this box 3 debt valuation does not apply to the borrower.

The temporary practical option to use nominal value

Calculating current value requires more than the principal. You also need the remaining term, repayment method, payment schedule, an appropriate market rate and any contractual options.

The Belastingdienst therefore temporarily permits taxpayers to report a monetary receivable or debt at nominal value until the Wet werkelijk rendement box 3 (Actual Return in Box 3 Act) enters into force.

Securities (effecten) as defined in Article 1:1 of the Wet op het financieel toezicht (Financial Supervision Act, or Wft) are excluded from this approval. Special structures should therefore be assessed separately.

The practical option comes with an important condition: you must follow a consistent approach over time. The nominal value you choose applies to both the deemed return and the actual return under the counter-evidence scheme (tegenbewijsregeling). When calculating actual return, you must also use nominal value for the loan's value at the beginning and end of the year and when the loan is acquired or disposed of.

In practice, this means:

• do not change methods from year to year solely because another method produces a lower tax charge;

• record the first year from which you apply your chosen method;

• retain the agreement, repayment schedule and any valuation calculation;

• ensure that lender and borrower use the same contractual information and valuation date.

The approval is not permission to report an arbitrary amount. If you choose nominal value, use the actual outstanding contractual balance on 1 January. If you use current value, you must be able to substantiate the assumptions behind the calculation.

When is a current-value calculation particularly relevant?

A current-value calculation becomes especially relevant when several of the following features occur together:

• a high principal;

• a long remaining term;

• a fixed interest rate for the full term;

• a clear difference between the contractual rate and the current market rate;

• an interest-only loan or one on which principal is repaid only much later;

• unusual contractual terms;

• doubts about the borrower's creditworthiness.

For a short-term, variable-rate or on-demand loan, current value will often be closer to the principal. Credit risk may reduce the receivable's value if it is uncertain whether all payments will be received.

The borrower's insolvency does not, by itself, reduce the value of the debt. For a reduction on that basis, the relevant consideration is the likelihood that the debt will be waived in part or in full.

The position does not provide a general valuation rule for a loan that may be repaid early without penalty. The example it addresses expressly excludes that possibility. According to the position, non-transferability does not in principle reduce the value automatically, although the facts of a particular case may lead to a different result.

Have a tax adviser or financial valuation specialist assess any complex or material valuation.

Keep deemed return and actual return separate

The valuation on 1 January and the return earned during the year are two separate steps.

For the deemed-return calculation for 2026, the Belastingdienst uses the value on 1 January. The provisional percentage is 1.28% for bank deposits, the final percentage is 6.00% for other assets, and the provisional percentage is 2.70% for debts.

Starting with the 2025 tax return, you can also report your actual return (werkelijk rendement). The Belastingdienst compares this with the deemed return and applies the more favourable outcome. The counter-evidence scheme applies to your entire box 3 position. You cannot elect to use it only for this family loan.

If you use current value for the loan, interest received and changes in value may count towards the actual return. If you choose the practical nominal-value option, you must also use nominal value here.

Under the actual-return calculation, no tax-free allowance applies and costs are generally not deductible. Interest payable on a box 3 debt does count as a negative regular return (negatief regulier voordeel). Keep the valuation-date figure and the return for the year as separate calculations in your records.

What does the planned new box 3 law mean?

The Dutch government intends the Wet werkelijk rendement box 3 to tax actual returns as far as possible from 1 January 2028. On 30 June 2026, however, the Dutch Senate (Eerste Kamer) postponed its vote while awaiting additional information.

As at 5 August 2026, the bill was therefore not final. Its details and effective date may still change. Because the temporary approval for nominal valuation is linked to the legislation entering into force, check the position again for every tax year.

Practical checklist for your tax return

Create a concise file for each family loan so that an independent person can follow how the return was prepared.

1. Determine the tax box for both parties. Record why the receivable or debt belongs in box 1, box 3 or elsewhere.

2. Record the position at 1 January. Retain the principal, repayments, interest rate and remaining term.

3. Choose and explain a valuation method. Use current value or the temporarily permitted nominal value.

4. Apply the method consistently and coordinate the data. Ensure that lender and borrower use the same contractual information and valuation date.

5. Retain the evidence. Keep the agreement, interest-rate evidence, repayment schedule and calculation with the tax return.

6. Review the position after a significant event. Examples include an interest-rate revision, debt waiver, payment difficulties or refinancing.

A well-drafted agreement remains the foundation. You can use a model contract for a private loan and record any subsequent amendments in writing.

Frequently asked questions

What value should I report for a family loan on 1 January 2026?

The statutory basis is fair market value on 1 January 2026. According to the Knowledge Group position, you may temporarily use nominal value if you apply it consistently to both deemed and actual return and the loan is not a security excluded under the Wft.

Must the lender and borrower use exactly the same value?

Not always. If the only relevant factor is an interest-rate difference, the receivable and debt in the Knowledge Group's example have, in principle, the same current value.

Uncollectibility may reduce the receivable, however, while the borrower's payment difficulties do not by themselves reduce the debt. For the debt, the likelihood of a partial or full waiver is decisive.

Can I change methods next year?

The position does not specify when a taxpayer may subsequently change methods. It states only that nominal value must be used consistently and that the choice must not be made solely to obtain a tax advantage. Have any proposed change reviewed in advance.

Is a market-conform interest rate enough to use nominal value?

No. The market rate can change after the agreement is signed. A loan that was originally market-conform may therefore later have a value above or below its principal.

Does this also apply to a family mortgage?

Yes. For the lender, the receivable arising from a family mortgage will generally fall in box 3. For the borrower, the debt may qualify as an owner-occupied home debt in box 1 if the conditions are met. Assess the tax position of each party separately.

Do I need a formal valuation?

Not necessarily. A verifiable calculation based on the contractual cash flows, remaining term and an appropriate market rate may be sufficient. Seek professional advice for large amounts, unusual terms or material credit risk.

Conclusion

A long-term fixed-rate family loan may be worth more or less than its principal for box 3 purposes. In the official example, a relatively high contractual interest rate increases the value of a 300,000-euro receivable to 319,701 euros.

For the time being, you may continue to use nominal value if you do so consistently and can demonstrate how the figure was determined. Choose the method deliberately, coordinate the underlying information between both parties and retain the supporting records.

Want to keep the agreed interest, repayments and amendments together in one place? FLUX5 helps families document a private loan clearly. For any material tax valuation, personalised advice from a tax adviser remains prudent.

Sources

• Belastingdienst Knowledge Groups, KG:202:2026:7 Valuation of receivables and debts in box 3, published 22 May 2026.

• Belastingdienst, How was the box 3 income on my provisional 2026 assessment calculated?, accessed 5 August 2026.

• Belastingdienst, What is my actual return?, accessed 5 August 2026.

• Belastingdienst, I borrow money for my own home from family, a private limited company or a foreign bank: may I deduct the interest?, accessed 5 August 2026.

• Dutch Senate, Actual Return in Box 3 Act (36,748), status accessed 5 August 2026.

• Government of the Netherlands, Government plans to tax actual returns in box 3, accessed 5 August 2026.

This article provides general information and is not personalised tax or legal advice. Rules, percentages and the treatment of your loan may change or depend on individual circumstances. Always check the latest information from the Belastingdienst before filing your tax return and consult a professional if you are unsure.