Netherlands Banking and Savings Tax Guide
Dutch banking and savings taxation — the bankenbelasting (bank tax — a levy of ~0.044% on bank liabilities above €20 billion and ~0.022% on the first €20 billion, payable by all banks operating in the Netherlands), the deposit guarantee scheme (depositogarantiestelsel — €100,000 per person per bank, administered by DNB, funded by bank contributions), the taxation of savings account interest (box 3 — the deemed return of 6.04% applies regardless of the actual interest rate of ~1–3%), the heffingvrij vermogen (exempt equity of €57,000 per person), the nieuwe box 3 (the new Dutch wealth tax proposed to replace the current deemed-return system with a tax on actual investment returns, but delayed by the Supreme Court), and the taxation of bank shares, AT1 bonds (contingent convertible bonds), and savings deposits for non-resident savers (the Dutch box 3 continuing liability for former residents and the CRS reporting of Dutch savings to foreign tax authorities).
Bankenbelasting (Bank Tax)
- Bank levy — ~0.044% of liabilities: The Netherlands imposes a bankenbelasting (bank tax) on all banks and credit institutions operating in the Netherlands. The tax is calculated on total liabilities (excluding Tier 1 capital and covered bonds) minus insured deposits (depositogarantiestelsel-exempt deposits). The rate is approximately 0.022% on the first €20 billion of taxable liabilities and 0.044% on liabilities above €20 billion. For ING (total liabilities ~€900 billion), the annual bank tax is approximately €200–300 million. The tax is deductible for corporate tax purposes.
- Who pays: The bank tax applies to: (a) banks with a Dutch banking licence (ING, Rabobank, ABN AMRO, NIBC, Van Lanschot Kempen, Triodos, Deutsche Bank Nederland), (b) branches of foreign banks operating in the Netherlands, and (c) credit institutions that are members of the deposit guarantee scheme. The tax is payable annually to the Belastingdienst. The revenue is earmarked for the general budget (not specifically for bank resolution or the deposit guarantee).
Deposit Guarantee Scheme (Depositogarantiestelsel)
- €100,000 per person per bank: The Dutch deposit guarantee scheme (depositogarantiestelsel) protects €100,000 per depositor per bank. The guarantee covers: current accounts (betaalrekeningen), savings accounts (spaarrekeningen), and term deposits (deposito's). The guarantee is administered by De Nederlandsche Bank (DNB). In case of a bank failure, DNB pays the depositor within 7 working days. The scheme is funded by the banks — each bank pays an annual contribution based on its risk profile and covered deposits.
- Temporary high balances — €500,000: Certain deposits are protected up to €500,000 for a temporary period of 6 months: (a) proceeds from the sale of a principal residence, (b) insurance payouts (death, injury, property damage), (c) severance payments, (d) inheritance proceeds, and (e) divorce settlement payments. The depositor must notify the bank of the temporary high balance and provide documentation within 3 months of the deposit.
Savings Accounts — Box 3 Tax Treatment
- Deemed return on savings: Savings account balances are included in box 3 at their 1 January balance. The deemed return (6.04% on total net assets above the first bracket) applies — not the actual interest earned. This means: if your savings account earns 2% interest but the deemed return is 6.04%, you pay tax on 6.04% of the total savings (not just the 2% interest). The effective rate is 6.04% × 36% = ~2.17% of the entire savings balance. This is a significant burden in a low-interest-rate environment — the system is designed to tax wealth, not income.
- Nieuwe box 3 — the future of savings taxation: The Hoge Raad ruled in the December 2021 Kerstarrest that the current box 3 system (flat deemed return on total net assets) violates the European Convention on Human Rights (right to property) because it taxes savings at a deemed return that exceeds the actual return. The government introduced a transitional system (overgangsregeling) and is working on a nieuwe box 3 — a tax on actual investment returns (not deemed returns). The new system is expected to apply from 2027–2028. Under the new system: savings are taxed at a separate deemed return (approximately 0.92% — closer to actual savings rates), while investments are taxed at a higher deemed return (approximately 7.2%). The transition is complex — we recommend monitoring the Belastingdienst's updates.
Bank Shares and AT1 Bonds for Individual Investors
- Bank shares — box 3 or box 2: Individual investors holding bank shares (ING, ABN AMRO, Rabobank certificates) are generally in box 3 — the shares are valued at market price on 1 January and subject to the deemed return. Dividends from bank shares are not separately taxable (the 15% dividend withholding tax is a final levy for individual investors). Substantial-interest holders (≥5%) holding bank shares through a BV are in box 2 (24.5–31% on dividends and gains).
- AT1 bonds (contingent convertible bonds): AT1 bonds issued by Dutch banks (perpetual bonds that convert to equity or are written down upon a trigger event) are box 3 assets for individual investors. The coupon (interest payment) is not separately taxable — the bonds are subject to the box 3 deemed return. For corporate investors (BVs), AT1 bonds are taxable at 25.8% on the coupon. The AT1 market in the Netherlands is significant — ING and ABN AMRO have issued AT1 bonds in euros and dollars.
For the full box 3 regime including the heffingvrij vermogen and the transitional rules, see our Investment and Box 3 Guide →. For the bank tax and its corporate tax treatment, see our Corporate Tax Guide →. For the deposit guarantee scheme details and DNB contact, see dnb.nl.