This month’s newsletter contains recent updates regarding the Netherlands, Switzerland, United Kingdom, and South Africa.

Please let us know if there are any specific subjects that you would like us to cover, by emailing us at info@oreana.com

Europe

🇳🇱 Netherlands

Taxing Actual Returns

The Dutch government has approved a major reform to the Box 3 tax system. The current system, which taxes savings and investments based on a notional rate of return, will be replaced by a new model that taxes actual returns.

From 1 January 2028, individuals will be taxed annually on both realised income and changes in the value of their assets, including unrealised gains. The existing approach of applying a deemed rate of return to all Box 3 assets will be abolished and replaced with a flat 36% tax on actual returns.

In addition, the previous tax-free capital threshold of approximately €57,600 will be replaced by a new tax-free annual return allowance of €1,800. No tax will be payable if an individual’s total Box 3 return falls below this amount.

The government has also passed a motion requiring the incoming administration to submit a further revised Box 3 proposal before Parliament opens in 2028.

🇨🇭 Switzerland

Individual Taxation

Swiss voters have approved the Federal Act on Individual Taxation, introducing a system that is no longer based on marital status.

Under the current system, married couples and registered partners are taxed jointly on their combined income. Due to Switzerland’s progressive federal tax rates, this often results in a higher overall tax burden compared with unmarried couples.

The new individual taxation system will assess each person’s income and assets separately. Every taxpayer will file their own tax return and declare income and assets according to civil law. The reform will apply at federal, cantonal, and municipal levels and is scheduled to take effect no later than January 2032. It represents one of the most significant overhauls of the Swiss tax system for private individuals in decades.

Cantons will be required to introduce new tax rate schedules and revise their allowance rules accordingly.

🇬🇧 United Kingdom

HMRC Tax Exemption for Expats Returning from the Middle East

HM Revenue & Customs (HMRC) has indicated it will consider granting tax exemptions to British expats returning to the UK from conflict zones in the Middle East.

Many of these individuals were not previously UK tax resident. However, under the UK’s Statutory Residence Test (SRT), spending 183 days or more in the UK in a tax year would normally trigger UK tax residency, resulting in taxation on worldwide income and gains.

Under the SRT, HMRC may disregard up to 60 days of UK presence in cases of “exceptional circumstances” beyond the individual’s control. It is important to note that this exemption typically applies to situations where a person is prevented from leaving the UK, not when they choose to return early because their overseas location feels unsafe.

Returning expats could also be affected by the temporary non-residence rules, which may result in certain capital gains realised while abroad becoming taxable in the UK.

HMRC has not yet clarified whether the 60-day limit can be extended or whether the exemption would apply where individuals are able to leave but consider it unsafe to do so. The last time a similar 60-day exemption was widely applied was during the COVID-19 pandemic.

Other  UK Tax Changes – April 2026 (Tax Year 2026/27)

• Dividend tax rates will increase by 2 percentage points: the basic rate will rise from 8.75% to 10.75%, and higher rates from 33.75% to 35.75%.
• The additional rate of dividend tax remains unchanged.
• The tax-free dividend allowance stays at £500.
• Shares listed on the Alternative Investment Market (AIM) will no longer qualify for 100% Business Property Relief (BPR). Instead, a flat 50% relief will apply to their full value (the 2-year holding period requirement remains).
• Upfront tax relief on investments in Venture Capital Trusts (VCTs) will be reduced from 30% to 20%.

Middle East & Africa

🇿🇦  South Africa

Approved tax-free Investment Products

From 1 March 2026, South African residents can invest up to ZAR 46,000 (approximately USD 2,700) per year in approved tax-free investment products, with all returns fully exempt from tax.

These tax-free investments can take the form of endowments, savings accounts, or unit trusts. Income, dividends, and capital gains generated within these products will be entirely tax-free.

Without this status, returns would normally be subject to:

• Up to 45% tax on interest income
• 20% dividends tax on South African dividends
• Up to 18% capital gains tax on capital gains

Any unused portion of the annual limit is forfeited and cannot be carried forward. A lifetime limit of ZAR 500,000 (approximately USD 22,350) per person also applies.

A 40% penalty will be imposed on any investment that exceeds either the annual or lifetime limit.