Dutch expat ruling in 2026 and 2027
20 February 2026
Do you work in the Netherlands with an expat ruling (formerly called 30% ruling)? Or do you employ staff who benefit from this facility? The expat ruling has been subject to significant changes and transitional rules in recent years and more have been announced. Below we outline what the ruling entails and the main developments employers and employees should be aware of.
The expat ruling is a Dutch tax facility for employees recruited or seconded from abroad. If all conditions are met, employers can grant a tax-free allowance up to 30% of the gross salary for a maximum of 5 years. However, in case the employee has lived or worked in the Netherlands during the last 25 years prior to the application of the 30% ruling, the maximum period of 5 years will be reduced by all periods of prior living or working in the Netherlands that have ended during the last 25 years.
To qualify:
- The employee’s taxable salary (excluding the allowance) must be at least € 48,013 in 2026 (indexed annually).
- For employees under the age of 30 with a qualifying Master’s degree the reduced threshold is € 36,497 (2026).
- The employee should have lived the last two years for more than 2/3 of the time beyond 150 kilometres of the Dutch border (16 of 24 months).
- Employer and employee must agree in in a separate addendum to the employment agreement to reduce the taxable salary of the employee to a maximum of 70% and that the employee is entitled to a net allowance of maximum 30/70, of the reduced wage.
- The application must be filed jointly by the employer and employee within four months of starting work in the Netherlands in order to apply the ruling retroactively.
- When the employee joins a new employer, the 30% ruling must be applied for again in the name of the new employer. The new employment needs to commence within three months of terminating previous employment.
Income cap (‘WNT-norm’)
The expat ruling does not apply to the portion of an employee’s taxable wage that exceeds the WNT norm. This cap is indexed annually and amounts to € 262,000 in 2026. Transitional arrangements will no longer apply from 1 January 2026.
Key changes to the expat ruling per 2027
Reduction of the maximum tax-free allowance
- From January 1, 2027, the maximum tax-free allowance will be reduced from 30% to 27%. For 2026, the 30% rate remains unchanged.
- Employees already receiving the allowance in December 2023 will retain the 30% rate for the remainder of their ruling period based on transitional rules.
Higher salary criterion
- As of January 1, 2027, the minimum required taxable salary will increase from € 48,013 to € 52.521 (based on 2026 figures, higher indexed amounts will apply in 2027).
- Lower thresholds apply for employees under 30 with a qualifying Master’s degree.
- Transitional rules apply for those receiving the allowance in December 2024. They can use the old (indexed) salary criteria until the end of their ruling
| Start date expat ruling | 2027 and further |
|---|---|
| No later than 31 December 2023 | 30% and current indexed salary criteria |
| In 2024 | 27% and current indexed salary criteria |
| From 1 January 2025 | 27% and new increased salary criteria |
These changes will result in three different regimes for employees under the expat ruling from 2027 onwards. It is important for employers to understand which regime will apply to their employees.
Abolishment partial foreign tax liability
As of 1 January 2025 the partial foreign tax liability is abolished. Until 2025 the partial foreign tax status allows employees to exclude specific foreign income (box 2 and box 3) from Dutch taxation
The abolition of partial foreign tax liability means that employees with an expat ruling residing in the Netherlands become taxable for their worldwide income in the Netherlands. Dutch personal income tax returns become more complex as residents need to report worldwide savings and investments. The above may result in higher personal tax liabilities.
For existing cases per December 2023 (employees who have already received an expat ruling allowance in December 2023), transitional rules will apply. For them, the abolition will apply as of 1 January 2027.
What you could do
- Review your or your employees’ tax position and find out which regime is applicable.
- Inform employees on changes in their tax position.
- If tax equalization or protection policies are applicable, also consider that employer’s costs can increase.
How Forvis Mazars can help
We offer:
- Assistance with the expat ruling request
- Tailored advice on the expat ruling and upcoming changes.
- Tax return preparation for employees with or without the expat ruling.
- Impact assessments and estimated tax calculations.
Contact us
Want to know how these changes affect you or your employees? Please feel free to contact us by phone or email. Our contact details are listed below.
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