Moving to Portugal from the US? Learn when Portuguese tax residency starts, how US taxes continue, when to get a NIF, and when to file Modelo 3.
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An American household in Amsterdam or The Hague plans across two tax systems that disagree about almost everything: what counts as income, when it is taxed, and even which return is due first in the spring. Neither system switches off. The United States taxes its citizens and green-card holders on worldwide income wherever they live; the Netherlands taxes its residents through a box system of its own design.
This article is aimed at US citizens and green-card holders living in the Netherlands - employees on the 30% ruling, families settled for the long term, and the professionals who prepare their returns. It is the orientation page for this series' Netherlands cluster: it maps the terrain, dates the moving parts, and points to the dedicated pieces on the 30% ruling and on Box 3 rather than repeating them.
This article describes how United States federal tax law and the U.S.-Netherlands income tax treaty apply to US persons. It summarises Dutch rules only as published by the Belastingdienst and in the Staats blad, for context, and is not Dutch tax, legal or succession advice - those questions belong with a Dutch-qualified professional.
The US side is blunt: "You are subject to tax on worldwide income from all sources and must report all taxable income and pay taxes according to the Internal Revenue Code" - citizenship or a green card is enough, an ocean away or not. The Dutch side turns on where you live: "If you live in the Netherlands, you have resident taxpayer status," and residence is judged on the facts of your life.
The Belastingdienst assesses residence on the circumstances - where your permanent home, family and economic life actually are - so the question is assessed on the facts, and close cases belong with a belastingadviseur. The treaty adds its own definition for tie-breaks: aresident is one "liable to tax" by reason of "domicile, residence, place of management," with a permanent-home and centre-of-vital-interests cascade for people caught by both systems.
The bridge between the systems is the Convention between the United States of America and the Kingdom of the Netherlands for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income, signed at Washington on 18 December1992 (the U.S.–Netherlands Income Tax Treaty), generally effective from 1January 1994 and amended by a 2004 Protocol in force since 28 December 2004.Like other US treaties it contains a saving clause preserving US taxation of US citizens; which allocations are excepted from that clause is a document-by-document question this series treats carefully, because the official texts retrievable online stop short of the full list.
Dutch income tax divides a person's affairs into three boxes and taxes each on its own logic. Box 1 covers income from work and home at progressive rates - for 2026, 35.75% up to €38,883, 37.56% up to €78,426 and 49.50% above that, as published for the provisional assessment. Box2 covers substantial shareholdings. Box 3 covers savings and investments - and taxes a deemed return, not your actual one.
Box 2 (belastbaar inkomen uit aanmerkelijkbelang) applies where you hold at least 5% of the shares in a company, Dutch or foreign: for 2026 the first €68,843 of such income is taxed at 24.5% and the excess at 31%. For an American shareholder this box travels with US rules on the same shares - dividends, gains and possibly the passive foreign investment company regime - so the two-return picture matters even before Box 3 enters.
Box 3 (income from savings and investments - in komen uit sparen en beleggen) is the box most Americans meet through their portfolios. For 2026 it assumes a 6.00% return on investments and other assets(a definitive percentage), provisional percentages of 1.28% on bank deposits and 2.70% on debts, taxes the assumed total at 36% above a tax-free allowance of €59,357 per person, and measures everything on 1 January. Whether you may instead evidence your actual return - and where the whole regime is heading by 2028 - is the subject of this series' dedicated Box 3 article.
The 30% ruling (30%-regeling, theexpatregeling) lets a qualifying employer pay a recruited-from-abroad employee up to 30% of salary free of Dutch tax for at most five years - in 2026, against a salary norm of €48,013 and capped at €78,600 of untaxed allowance. Its terms change by statute year: the Belasting plan 2025 withdrew the 30/20/10 phase-down from 2025, and the Rijksoverheid states the maximum falls to 27% from 1 January2027 - a term a future Belastingplan could amend.
Which percentage and which salary norm apply to a given employee depends on when the ruling was first applied - the published transition runs in three cohorts (by end-2023, during 2024, from2025) - and the separate partial foreign tax liability election, which kept a ruling-holder's non-Dutch investment income out of Box 3, was abolished by the Belastingplan 2024 with effect from 1 January 2025, with transitional use forpre-2024 ruling holders that the Belastingdienst publishes as running through the 2026 tax year. The dedicated 30%-ruling article in this series walks every date, cohort and figure with sources.
Two filing calendars run in parallel. The US return keeps its Form 1040, with the automatic two-month extension to 15June for Americans abroad and interest still running from April; FinCEN Form114 (FBAR) and Form 8938 sit alongside it once account values cross their thresholds. The Dutch aangifte inkomstenbelasting must, in invitation cases, be received before 1 May - and the year you arrive or leave has its own form.
The M form (M-biljet) deserves its own line in any moving-year plan: it is the only way to file for a year in which you were resident for part of the year, and it is what catches split-year facts the standard form cannot. One piece of US paperwork usually does not apply: disclosure of a pension or social security treaty position on Form 8833 is generally waived by regulation — the substantive analysis still has to be done.
The Dutch state describes its pension system as three pillars: the AOW state pension as the basic first pillar, supplementary pension built through the employer as the second, and individual products such as lijfrenten as the third. AOW accrues at 2% of a full pension for each insured year in the 50 years before AOW age - 67 in 2026 and 2027, 67and 3 months in 2028 as published - so years lived outside the Netherland sleave proportionate gaps.
On the treaty's consolidated text, private pensions and annuities are taxable only in the residence state, with a source-state right over certain lump sums and non-periodic payments, and social security payments are taxable only in the paying state - though the officially published texts retrievable for this series stop short of the saving-clause exceptions list, so how each allocation lands for a US citizen is presented here as the professionals' question, not a settled chain. Separately, the U.S.–Netherlands totalization agreement, in force since 1 November 1990,coordinates social security coverage and lets six-plus US quarters combine with Dutch periods for a pro-rated benefit - "your credits are not actually transferred from one country to the other" - and it does not address income taxation of benefits. The retirement deep dive belongs to this series' cross-cutting pieces, not this page.
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The investing problem is the same one this series meets in every country, with Dutch labels. A Dutch or EU-domiciled fund held by a US person will typically meet the passive foreign investment company tests of Section 1297 - the 75% income test or the 50% asset test - bringing Form 8621's regimes with it, while FATCA (the Netherlands has a Model 1intergovernmental agreement, in force since 9 April 2015) is why Dutch institutions ask US-person questions.
The practical questions - whether a US brokerage will keep serving a Netherlands address, and what to do if it will not - are covered in this series' companion pieces on keeping US brokerage access (/us-brokerage-closing-expat-accounts) and on the PFIC problem with non-US funds (/pfic-ucits-funds-foreign-nationals-us-residents); the euro-dollar dimension of holding wealth in two currencies has its own piece(/currency-americans-switzerland-uk-eurozone). This page deliberately does not restate them - and how those same accounts meet Box 3's deemed return is the dedicated Box 3 article's subject.
Estate planning gets one dated line here: the Netherlands appears on the IRS's list of estate tax treaty partners - listed for estate tax - so a U.S.–Netherlands estate tax treaty exists - the opposite of this series' Portugal finding. Everything beyond that line - the2026 US exemption figures, mixed-nationality couples, situs and credits - lives in the series' estate pieces (/2026-estate-tax-changes-american-families and/mixed-nationality-couples-us-estate-tax) and is deliberately not restated on this page.
The team, then. On the Dutch side: a belastingadviseur for income tax, the boxes and any ruling questions, and a notaris where Dutch wills, property deeds or succession documents are involved. On the US side: a CPA or Enrolled Agent with expatriate experience, and a US estate attorney where the estate crosses the ocean. A cross-border financial planner's job is to make those professionals' work fit together - not to substitute for either.
No - it allocates, and someone still has to claim the relief. The treaty assigns taxing rights article by article, but its saving clause preserves full US taxation of US citizens, so an American's relief usually arrives through Article 23 and the foreign tax credit rather than through exemption. On the Swiss side, Article 23(1)(a) works by exempting US-taxable income with progression. Which mechanism applies to which income, and what the texts leave open, is worked through in the retirement article of this series.
No - but it is changing on a legislated timetable, and the dates matter. The 30/20/10 reduction enacted in the Belastingplan 2024 was withdrawn by the Belastingplan 2025 (adopted 17 December 2024) with effect from 2025; in its place, the Rijksoverheid states the maximum untaxed allowance falls from 30% to 27% from 1 January 2027, with higher salary norms and transitional treatment by the date the ruling was first applied - terms a future Belastingplan could amend. Separately, the partial foreign tax liability election was abolished by the Belastingplan 2024 with effect from 1 January 2025; the Belastingdienst publishes transitional use for pre-2024 ruling holders through the 2026 tax year. The dedicated article dates every step.
Box 3 is the Dutch tax on income from savings and investments - computed not on what your assets earned but on a deemed return: for 2026, 6.00% on investments and other assets, at a 36% rate, above a €59,357 per-person allowance, measured on 1 January. A US brokerage account held by a Dutch resident sits inside that computation while the United States taxes the same account on actual dividends and gains. The mechanics, the counter-evidence rule and the planned move to actual-return taxation are covered in this series' dedicated Box 3 article.
Yes. US citizens and green-card holders are taxed on worldwide income wherever they live - the IRS states it directly: "You must pay U.S. income tax on your foreign income regardless of where you reside." Filing thresholds track the standard deduction ($16,100 single, $32,200 joint for 2026), and married-filing-separately triggers at just $5. Americans abroad get an automatic two-month extension to 15 June, though interest runs from the April due date. The Dutch aangifte runs in parallel - one return does not replace the other.
Liam Fraboulet is a Private Wealth Adviser specialising in cross-border wealth management for Americans living abroad. He works with U.S. citizens, internationally mobile professionals, and families whose financial lives span more than one country, helping them build, protect, and transfer wealth across borders.
Whether clients are advancing their careers overseas, raising a family abroad, preparing for retirement, or planning for future generations, Liam helps them create joined-up financial strategies that reflect their personal goals and the international lives they have built.
This article is provided for general educational and informational purposes only and does not constitute personalised investment, tax, accounting, legal, pension or financial advice. Dutch tax, legal, social-security and succession rules can depend on individual circumstances and should be reviewed with appropriately qualified Dutch professionals. US citizens and green-card holders should consult a qualified US tax professional regarding their individual US filing, treaty, foreign-tax-credit, FBAR, FATCA and PFIC obligations. Tax laws, regulations, treaty interpretations and administrative guidance can change, and information stated in this article may become outdated. No information in this article should be interpreted as a recommendation, offer or solicitation to buy or sell any security or financial product, or as a guarantee of any particular tax, investment or financial outcome.

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