The Dutch 30% ruling is undergoing significant changes that will impact international employees and employers alike. These updates affect tax benefits, compliance obligations, and overall tax exposure.

In our latest brochure, we provide an overview of these developments and what they mean in practice.

Key changes to the Dutch 30% ruling

1. Abolition of Partial Non-Resident Taxpayer Status

One of the most impactful changes is the abolition of the partial non-resident taxpayer status as of 1 January 2025. Existing 30%-holders with the partial non-resident taxpayer status will lose this status in the course of 2026. As a result, they and newer 30%-holders (since 1 Januari 2025) will become fully subject to Dutch personal income tax on:

• Foreign substantial interests (Box 2)
• Savings and investments (Box 3)

This change may significantly increase tax exposure and compliance complexity, particularly for individuals with foreign assets.

2. Introduction of a Salary Cap (Balkenende Norm)

The 30% ruling is now subject to a maximum salary cap. For 2025, this is set at EUR 246,000. For the running year 2026 this is Euro 262.000.

• The 30% tax-free allowance applies only up to this threshold
• Any excess salary is fully taxable

A transitional regime applies for certain employees until 2026.

3. Reduction to a 27% Ruling from 2027

From 1 January 2027, the tax-free allowance is expected to be reduced from 30% to 27%.

In addition:

• Higher minimum salary thresholds will apply
• Transitional rules may allow existing beneficiaries to retain the 30% benefit temporarily

Impact on Dutch personal income tax

The Dutch tax system consists of three “boxes”:

• Box 1: Employment income and (deemed) income from primary residence
• Box 2: Income from substantial interests (≥5% shareholding)
• Box 3: Savings and investments

With the removal of the partial non-resident status, more income and assets will be subject to Dutch personal income tax, making tax returns more complex and potentially increasing the overall tax burden.

What does this mean for expats and employers?

These changes will likely:

• Increase Dutch tax exposure for international employees
• Require more detailed reporting of foreign assets
• Lead to more complex and time-consuming tax filings

We strongly recommend reviewing your tax position in advance, especially if your partial non-resident taxpayer status is expected to end soon or in cases where your 30% ruling ends in the course of the year.

Download the full guide

Download our brochure: Key Changes in Dutch Tax Treatment for International Employees, using the button below.

Get expert advice

If you would like to understand how the Dutch 30% ruling changes affect your personal situation or your workforce, feel free to contact our team.