Employing in the Netherlands: a whole new playbook

A shifting expat regime with declining competitive edge

One of the most visible changes concerns the Dutch expat regime, until recently better known as the 30% ruling. While it remains a key tool for attracting international expertise, its competitive advantage is gradually eroding. “The Dutch expat scheme remains important,” says Rasink, “but its competitive edge is shrinking, especially the removal of the exemption of tax on wealth (Box 3) for expatriate employees. That is a game changer.”

The Netherlands has been rethinking parts of its preferential tax treatment for qualifying expats. Alongside the gradual reduction of the 30% ruling to 27%, there is increasing pressure on the favourable treatment that effectively exempted many expats from Box 3, the Dutch wealth tax regime.

“When those advantages are reduced or removed, net after-tax compensation for many international hires will fall,” Rasink explains. “That makes the Netherlands less attractive compared with other business hubs.” For employers, this marks a clear shift. Tax incentives alone are no longer sufficient. “The expat regime should be viewed as one element of a broader ‘total mobility proposition’,” Rasink says. “Flexibility, career development and international opportunities are at least as important as tax incentives when attracting global talent.” For further detail on the 30% ruling, see the related article.

International remote working: flexibility versus complexity

Remote working has become a core component of international employment. It offers flexibility, but also introduces significant tax, social security and legal risks. “International remote working has effectively become the standard form of international mobility,” Rasink explains. “It is often perceived as simple, but even short periods abroad can have tax, social security or employment law implications.”

Hybrid working models have supported an increase in the number of employees working temporarily from another country. While this creates opportunities, it can also trigger payroll withholding obligations, social security mismatches and permanent establishment risks. Some countries take a broad view of when an employee’s presence creates a taxable presence for the employer.

The OECD’s recent public consultation on the global mobility of individuals reflects these realities. It explores practical solutions such as workday thresholds for short-term cross-border work, streamlining employer compliance obligations, re-examining how employment income is sourced, and improving coordination between tax and social security rules. “Until those are implemented, if at all, employers need to manage the risks themselves,” Rasink notes. That starts with clear policy and with breaking down internal silos. “What was once mainly an HR-issue now requires coordination across HR, tax, legal and payroll functions,” he says. Organisations need to define where employees can work from, for how long, and under what approval process. A practical “where you can work” policy, supported by tracking tools and auditable approvals, is becoming essential.

For tracking short-term travellers, Forvis Mazars works with Track Global. This tool monitors cross-border days, immigration status, visa and work permit requirements, and flags payroll, social security and permanent establishment risks. For further insights into these OECD developments, see the related article.

Uber ruling reinforces importance of the factual working relationship

Developments around the use of self-employed workers are equally significant. The recent Uber court ruling confirms that determining whether a self-employed individual qualifies as an employee requires a fully holistic assessment. “Entrepreneurship matters,” Rasink says, “but it never outweighs the totality of circumstances. Individual facts always prevail.”

Dutch case law shows that courts and authorities look closely at how work is performed in practice. If a worker operates under direction, performs company core activities over a prolonged period and bears little entrepreneurial risk, the relationship may be classified as employment. For organisations relying on freelancers, contractors or platform-based models, this is a clear warning. “A well-drafted contract offers limited protection if the day-to-day reality points to employment,” Rasink emphasises. “Businesses should therefore review not only their documentation, but also how contractor roles are structured in practice.”

Enforcement on false self-employment returns in 2026

This issue is becoming more urgent. From 1 January 2026, the Dutch tax authorities have resumed regular enforcement on false self-employment. “Companies must realise that enforcement is back,” says Rasink. “Retroactive assessments, social security and pension claims, and fines are realistic outcomes where authorities conclude there is disguised employment.”

At the same time, the Dutch government is working on further clarification of self-employed status in legislation through the ‘zelfstandigenwet’ trajectory, replacing the previous ‘Vbar’. But waiting for final legislation is not a strategy. “A practical first step is a full review of the existing external workforce,” Rasink advises. “Which roles are filled by freelancers, and do those roles genuinely reflect independent entrepreneurship?” Employers should risk-score contractor roles, apply objective status tests and proactively address high-risk arrangements. “This is not just a compliance issue,” he adds. “It is also a question of workforce design and long-term resilience.”

Growing focus on pay transparency and further staffing developments

Another major development is the increasing focus on pay transparency, driven by EU legislation and the Equal Pay Directive. While implementation differs across Member States, the direction is clear and the Netherlands is moving towards new transparency requirements.

“Pay transparency goes beyond regulatory compliance,” Rasink notes. “It directly affects employee trust and employer reputation.”

He also points to an additional development on the horizon: the certification of temporary work agencies, which will further impact how organisations manage flexible labour. For more on this development, see the related article.

From compliance to strategic advantage

Across all these developments, one common thread stands out. Employers can no longer treat tax, HR and employment law as separate areas. Decisions around expats, remote working, freelancers, temporary labour and compensation increasingly intersect. “The organisations that will stay ahead are those that integrate policy across functions, translate rules into clear internal processes, and support implementation with the right tools and governance,” Rasink explains. That approach does more than reduce risk. It strengthens a culture of compliance, improves workforce planning, increases transparency and enhances employer reputation. “International employers in the Netherlands are entering a period of significant change,” Rasink concludes. “But organisations that approach these changes strategically can turn regulatory pressure into an advantage.”

With multidisciplinary teams and an international network, Forvis Mazars supports organisations in navigating these developments, combining expertise in tax, payroll, employment law, compensation and benefits, and technology to help build future-proof workforce strategies.