From 2026, investing privately will become significantly more expensive. Not because the tax rate is increasing – it remains at 36% – but because the deemed return on investments will rise: from 5.88% in 2025 to 7.78% in 2026.
At the same time, the tax-free allowance will drop to €51,396 per person. For many investors, this means a higher tax burden in Box 3. It’s no surprise that more people are looking for alternatives. One of those alternatives is transferring assets into a private limited company (BV) with a STAK. But how does that work, and is it a smart solution?
A STAK, or Stichting Administratiekantoor, is a legal structure that holds shares in a BV and issues certificates to certificate holders. The STAK has legal ownership and voting rights, while the certificate holders retain economic rights to the assets and profits. This structure is often used to separate control from economic ownership. Why is this interesting? Because a STAK allows you to structure your wealth, maintain control, and at the same time transfer assets to the next generation. Parents remain in control through the STAK board, while children receive certificates that entitle them to profits.
How does this work in practice?
Imagine you have €1 million in private investments. In Box 3, from 2026 onwards, you pay tax on a deemed return of 7.78%, which amounts to roughly €28,000 per year.
If you transfer this wealth into a BV via a STAK, you pay:
- Corporate tax on the actual profit in the BV (19% up to €200,000, then 25.8%).
- Box 2 tax only when dividends are distributed (24.5% / 31%).
This means you can defer tax and sometimes reduce it, especially if your actual returns are lower than the deemed return. However, note that when Box 3 moves to taxation based on actual returns (planned for 2028), this advantage will diminish.
When should you consider a STAK?
A STAK adds real value for estate planning:
- You can gift certificates to children, making them economic owners.
- You retain control through the STAK board.
- You can take advantage of gift exemptions and succession planning.
But setting up a STAK is costly and complex. You need a BV, a foundation, notarial deeds, and a governance structure. It only makes sense for substantial wealth (think at least €1 million) and if you have a gifting strategy.
Is a STAK the ultimate way out of Box 3?
Not in the first place and not always.
- For assets under €1 million, the costs often outweigh the benefits.
- If you don’t have a gifting plan, a STAK adds little value.
- And when Box 3 moves to actual return taxation, the tax advantage will shrink.
A STAK is not a quick fix but a strategic tool for wealthy individuals who want to:
- Transfer wealth to the next generation.
- Maintain control.
Want to learn more about STAK or smart ways to reduce Box 3 tax? Schedule an introductory meeting on our website and discover which strategy fits your situation best.