Expat Ruling (30%/27% ruling)
Incoming employees with scarce expertise can receive part of their salary tax-free: 30% through 2026, 27% from 1 January 2027, for a maximum of 5 years. The employer applies; the Tax Administration decides. A key lever for relocating senior design talent to the Netherlands.
Key parameters
| Tax-free share | 30% through 2026; 27% from 1 Jan 2027 |
|---|---|
| Salary threshold (from 2027) | €50,436 (€38,388 for masters under 30) |
| Duration | Max 5 years |
| Partial non-resident status | Abolished 1 January 2025 |
| WNT remuneration cap | Applies since 1 Jan 2026 for all users |
| Transitional rules | Pre-2024 users keep 30%; pre-2023 users also keep partial non-resident status through 2026 |
Eligibility
- HQ
- Any headquarters country
- Local presence
- Local tax presence required (branch is sufficient) A branch office (Zweigniederlassung/permanent establishment) of your existing company is enough — you do not need to form a new legal entity such as a GmbH or BV.
- R&D substance
- Not required
- Company size
- No size restriction
- Models
- All
- Sectors
- All
- Goals
- Additional design site in Europe
Employee must be recruited from abroad (>150 km from the Dutch border for 16 of the last 24 months) and meet the salary norm. The Dutch entity must be a registered withholding agent.
Mechanism & application
Rule-based entitlement — Legal entitlement — self-assessment, no case-by-case funding decision.
Joint application by employer and employee to the Belastingdienst within 4 months of the employment start for retroactive effect.
Timeline: Decision typically within 10 weeks
Legal basis & sources
- Legal basis
- Wet op de loonbelasting 1964, Art. 31a(2)
- Verification
- business.gov.nl / Belastingdienst
Changelog
-
1 Feb 2025
30-20-10 step-down proposal replaced by flat 27% from 2027.
Source: Belastingplan 2025 / business.gov.nl
Related
See also