Supreme Court considers that Box 3 taxation is still contrary to the ECHR and drafts compensation scheme
The Supreme Court concluded that tax assessments must be reduced so that only the actual return is taxed in Box 3, and it also provides rules for determining the actual return.
The memorandum in response to the report provides answers to many questions, but there are still many points that need further elaboration, especially at the OECD level.
The new treaty will apply at the earliest from January 1, 2024 (but probably only from January 1, 2025). We have summarized some important aspects of the new treaty.