Tax

30% ruling becomes 27% per 2027: what do we know so far

Sander Agterhof
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30% ruling becomes 27% per 2027
In the last years we had multiple changes regarding the benefits of the 30% ruling. Based on the Budget Day 2024 announcement we learned that one of the previously announced changes will be canceled and new changes are announced. The newly announced changes will be less harmful to the Dutch business climate. The actual rules are expected to be published around end October 2024 in the “nota van wijziging” of the 2025 Tax Plan. However we’re happy to share an overview of the announced changes and figures we currently know.

Previous changes

In the last years we had the following changes:

  1. The introduction of the “salary cap” has been adopted per 1 January 2023, transitional rules apply. See more details in our previous article.
  2. The introduction of the 30/20/10% rule has been adopted in the tax rules per 1 January 2024, transitional rules apply. With this rule the tax free percentage is reduced every 20 months with 10%. So eventually, employees will a receive a maximum of up to 10% tax-free allowance instead of 30%.
  3. The cancellation of the partial non-residency treatment has been adopted in the tax rules per 1 January 2024, transitional rules apply. Employees who receive the 30% ruling have the possibility to choose for the partial non-residency treatment. These employees have a very limited (or no) obligation to report and pay income tax over their private investment income (Box 2 and Box 3) in the Netherlands during the period the 30% ruling is applicable (in principle five years).

Developments on Budget Day 2024 regarding the 30% ruling

Based on the published documents of Budget Day 2024 we learned that the announced 30/20/10% rule (2. mentioned above) will be cancelled. The other two changes mentioned above (1. and 3.) will remain applicable. 

In addition, the percentage of the tax-free allowance will be reduced to 27% per 1 January 2027 and the salary level to qualify for the 30% ruling will be increased. Transitional rules will be applicable for employees who had the 30% ruling before 2024. These employees will keep a tax-free allowance of up to 30% during the total period of the 30% ruling. In addition, the salary level remains the same, although it will be subject to annual indexation.

This means that the employees who received the 30% ruling in 2024 or later, no transitional rules will apply. These employees will receive a maximum of 27% tax-free allowance as of 2027. The announced higher salary norm will also be applicable for this group as of 1 January 2025. Potentially this could mean that a part of the group who received the 30% ruling in 2024 will lose the 30% ruling if they no longer meet the new salary criteria in 2025 or onwards.

As mentioned, the actual (transitional) rules have not yet been published, so we will update this article once possible. In the below overview we show the actual figures we currently know: 

Table - 30% ruling

*Remains 30% if transitional rules apply
** Not relevant for 2024 - applicable per 2025

To be continued!

Sander Agterhof
Sander Agterhof , Partner
We will keep you updated on further developments. Meanwhile, if you have any questions regarding the 30% ruling please feel free to contact me.