In this leaflet we provide you with an overview of the key aspects of the Dutch 30% ruling for inbound expatriates (hereinafter “30% ruling”).

General

The 30% ruling is a Dutch wage tax facility, which basically allows an expatriate to receive up to a maximum of 30% of his or her salary from current employment tax-free. This facility applies to expatriates who are recruited or assigned to work in the Netherlands and qualify as an inbound employee.

In order to qualify for the 30% ruling, the following conditions must be met:  

  1. The employee must be recruited or assigned from abroad;
  2. The employer must be registered in the Netherlands as a withholding tax agent for payroll taxes;
  3. The employee must have specific expertise that is scarce or unavailable on the Dutch labour market. An employee has specific expertise if the salary meets the salary requirement (at least € 48,013 per year in 2026, excluding the tax-free allowance, or € 36,497 for an employee aged under 30 with a qualifying master’s degree at university level);
  4. In the period of 24 months prior to the employement in the Netherlands, the employee must have lived more than two thirds (16 months) of the 24 months farther than 150 kilometres from the Dutch border (distance criterion).   

Application

For the application the following documents must be provided to the Dutch Tax Authorities:

  • Completed application form;
  • Dutch citizen service number (BSN) of the employee;
  • Full address of the employee;
  • Employee’s CV;
  • Date of employee’s arrival in the Netherlands;
  • Copy of a master’s degree certificate obtained from an institute of university education if the employee is aged under 30 and proof it meets Dutch University standards if the employee wishes to use the lower salary requirement (€ 36,497);
  • A signed power of attorney of the employee to apply for the 30% ruling (if filed by a third party); 
  • A signed power of attorney of the employer to apply for the 30% ruling (if filed by a third party). 

In order to establish if the employee was living outside of the Netherlands at the time the employment contract was signed, additional documents should be provided:

  • Supporting documents that the employment contract was agreed before the day the employee entered the Netherlands;
  • Copies of bank account statements for a continuous period of 24 months up and until the date of arrival in the Netherlands (one page/excerpt per month is sufficient);
  • A marriage certificate (for married persons);
  • A copy of the residence & work permit (for non-EU nationals)
  • A rental / tenancy agreement or home purchase agreement in the Netherlands;
  • Valid identification of employee (passport or ID-card).

Application, timelines and 30% ruling decision

The application for the 30% ruling is a joint request by the employer and the employee and must be filed with the tax office in Heerlen within four months after the start of the employment activities in the Netherlands.

If the application is not made within four months, the facility will only be granted as of the first day of the month following the month in which the application is filed.

The 30% ruling can either be applied as per the date per which the 30% ruling decision has been granted by the Dutch Tax Authorities or pending the Dutch tax authorities’ decision on the request. In case of the latter, a denial of the request will mean that the payroll needs to be corrected and the additional tax reclaimed from the employee.

Duration of the 30% ruling

The employee can benefit from the 30%-ruling for a maximum period of five years. Qualifying periods of earlier employment or presence in the Netherlands in – or that ended in – the 25 years prior to the start of the current Dutch employment will be deducted from the total length of the 30%-ruling.

The employee should complete part 4 of the 30% ruling application form in which questions are asked in relation to earlier periods of work and residence in the Netherlands. This includes information on whether the employee has lived, worked or been physically present in the Netherlands for private reasons in the 25 years prior to the first working day at your company. Furthermore, this includes information on whether the employee has previously worked or resided outside the Netherlands whilst being an employee under Dutch law.

Changing jobs

Maintaining the 30% ruling in case of a change of jobs is possible. In that case, the employee and (new) employer must have a new employment agreement in place within three months of termination of the previous employment.

In addition, the new application request must be filed within four months after the start of the new employment for it to have retrospective effect as of the start date of the new employment. This application procedure is also a joint request by the new employer and employee.

Addendum to the employment agreement

In case of an application for a 30%-ruling, it is strongly advisable to have a clause in the employment agreement or a written addendum to the employment agreement.

The clause or addendum should amongst others explicitly state that the gross salary of the employee will be reduced by up to a maximum of 30% of wage from current employment, such in accordance with prevailing Dutch wage tax legislation and regulations, which are subject to change.

Please consider that a reduction of the gross salary also implies a lower basis for pension (less pension building up) and social securities (e.g. unemployment benefits or disability insurances).

30%-ruling cap

As of January 1, 2024, the advantage of the 30% ruling was capped. Starting from this date, employers can reimburse a maximum of 30 percent of income up to the 'WNT norm' — also known as the 'Balkenende standard' — tax-free.

Based on the 2026 WNT norm, the maximum tax-free reimbursement amounts to 78,600 euros per year. If an employee does not work in the Netherlands for the entire year, the amount will be calculated on a pro rata basis.

Announced changes per 2027

From January 2027, the 30% rule will be changed to a 27% rule. This means that the maximum tax-free allowance will be reduced from 30% to 27% of the taxable gross salary.

In addition, the salary standards will be increased. Employees will then be subject to a minimum salary of € 50,436 per year to qualify for the scheme. A lower standard of € 38,388 will apply to employees under 30 with a Dutch or comparable master’s degree.

These changes apply only to individuals who start using the 30% facility on or after January 1, 2024. Those already benefiting from the facility prior to January 1, 2024, will remain unaffected and will continue to receive 30% of their gross salary tax-free throughout the runtime of their 30%-ruling grant.

Partial non-resident taxpayer status

Up until the year 2024, an employee with a 30% ruling could also choose to be treated as a partial non-resident taxpayer for tax purposes in the Netherlands. This entails that the employee will be qualified as a foreign taxpayer for income from substantial interest (Box 2 of the Dutch income tax) and income from savings and investments (Box 3 of the Dutch income tax). In that case, as a foreign taxpayer the income to be reported is limited to Dutch source income for Boxes 2 and 3 and not to its worldwide (investment) income.

From the year 2025 onwards, this option was abolished. However, there will be transitional legislation through December 31, 2026. This means that employees who used the 30%-ruling prior to 2024 can still choose for the partial foreign tax liability until December 31, 2026. After 2026, employees will no longer be able to opt for the partial non-resident taxpayer status.

For employees that are U.S. nationals/Green Card holders, the choice means that they are treated as non-resident taxpayers of the Netherlands for purposes of the U.S.-Netherlands tax treaty.This means that they are only taxable in the Netherlands on employment income related to Dutch workdays and other specific sources of Dutch income.

The choice to be treated as a partial non-resident taxpayer must be made each year in the Dutch income tax return and is only applicable to holders of a 30%-ruling that fall under the transitional measures per above.  

More information? 

Should you have any comments or questions, or if you require our assistance, please contact your trusted RSM advisor.