Carried interest in the Netherlands

How is carried interest taxed in the Netherlands?

Carried interest is usually taxed as Box 1 income, at rates up to 49.50%. The Netherlands treats it as a reward for your work, not as a capital gain.¹

The Dutch call it a lucratief belang, a lucrative interest. It covers share rights you receive because of what you do, not because of what you invest. Fund carry and sweet equity in a scale-up are the common examples.

This surprises people who move here from the US or UK. There, carry is often taxed at a lower capital-gains rate. Here it falls in Box 1, alongside your salary, as income from other activities (resultaat uit overige werkzaamheden).

Take Mateo. He moved to the Netherlands for a private-equity role and holds carry in his fund. He files his first Dutch return this year and wants to know what he owes. We follow his situation through this page. Box 1 and Box 2 rules apply equally to fund carry and sweet equity.

When do your shares count as a lucratief belang?

They count when you get them as a reward for your work. The return can then run out of proportion to what you put in. The law lists the situations that trigger it.¹

A subordinated share class is the classic case. Your class ranks behind the rest and is under 10% of the total share capital. Then it falls under the rule. Preference shares that pay a dividend of 15% or more per year also qualify.

Buying the shares below market value or with a lot of leverage can bring them in too. The point is the same each time. You get an outsized return because of your role. So the Netherlands treats that return as pay.

For Mateo, this is his fund carry. His share class sits behind the investors and forms a small slice of the total. So it is a lucratief belang.

What do you pay in Box 1?

You pay the same progressive rates as on your salary, up to 49.50% in 2026. The Belastingdienst adds your carry to your other Box 1 income for the year.²

One relief is worth naming, but only for a directly held interest. A loss on a lucratief belang is then deductible in Box 1. Through the Box 2 route, the loss belongs in Box 2 instead. The exact scope depends on your situation, so we confirm it with you rather than assume it.

Most people who hold carry already earn above the top threshold from their salary. For them the top rate applies to the whole carry. The table below shows the 2026 brackets below the AOW pension age, the Dutch state pension age.

Can your carry be taxed in Box 2 instead?

Yes, if you hold the interest through a holding. You then pass at least 95% of the year's benefit to yourself in the same year. This is the doorstootregeling.³ If the carry arrives late in December, a January payout is too late. The doorstoot then fails and Box 1 applies instead.

It only works for an interest you hold indirectly, through your own holding company (middellijk gehouden). Then that benefit falls in Box 2 instead of Box 1. That is the box for a substantial shareholding. You need at least 5% ownership of that holding company yourself.

Box 2 has two rates in 2026. You pay 24.5% up to €68,843 and 31% above it. That sits well below the 49.50% top rate in Box 1. That is why the route matters.

The condition is strict, and the structure has to be right first. So this is a decision to plan, not to discover at filing time.

Box 1 or Box 2: what does the difference cost?

On this carry, the Box 2 route cuts the tax by over 40%. The route you can use depends on how you hold the interest.

Take Mateo again. Suppose €200,000 of carry pays out in 2026, on top of a salary already above €78,426. Held directly, all of it is Box 1 income at 49.50%, so about €99,000 in tax.

He could instead hold it through his holding and pay out 95% that year. Then the doorstootregeling puts it in Box 2. There he pays 24.5% up to €68,843 and 31% above, about €57,500. The table follows both routes. The 95% payout is the condition for the route, not the amount taxed. The comparison assumes the holding pays no corporate tax on the carry first.

Whether the Box 2 route is open to Mateo depends on his structure and the timing. His exact Box 1 figure depends on his other income. So we work it through with him before he files.

What changes for carried interest in 2028?

From 2028 the Box 2 route on an indirect carry gets more expensive. A base-broadening measure raises what you effectively pay.⁴

Parliament decided this in the 2026 Tax Plan. It enacted the measure but moved its start date to 1 January 2028. It counts as settled law waiting to take effect, not a proposal.

From 2028 a factor of 36/31 raises the taxable base on an indirect lucratief belang before the Box 2 rate applies. That lifts the effective burden to about 28.45% in the first bracket and 36% in the second. The Box 2 advantage shrinks, but it does not disappear.

For anyone planning around the doorstootregeling, this is the date to keep in view.

What does this mean for you?

Your structure decides your options, so start there. Look at how you hold the interest, directly or through a holding. Then look at the timing, since the Box 2 route needs the payout in the same year. If you hold your carry in a foreign fund or holding, the treaty and the reporting matter too.

For Mateo that means checking his structure before the next payout. Your carry is not reported for you, so you declare it in your annual return. You can see how we handle a full return on our page about the Dutch tax return.

How the Dutch tax system treats what you earn is on our overview of work and income.

Arrived mid-fund or leaving the Netherlands? We check how that timing affects your carry. Tell us when you arrived and where the fund is based. We then check whether a tax treaty gives relief.