Netherlands · Tax regime
30% expat ruling (extraterritorial costs scheme)
Still 30% for 2026. Drops to 27% from 1 January 2027 for anyone whose ruling started on or after 1 January 2024; rulings that started before 1 January 2024 keep 30% for their full 5-year term. Note that the 2024 stepped 30/20/10 taper was scrapped before it fully bit and is NOT the current law — a common source of stale advice.
The ruling has been cut, restored, re-cut and re-scoped four times in three years, and the ground is still moving. What matters most for UHNW families is not the 30-versus-27 percentage — it is the collapse of the partial non-resident status attached to it, which was always the real prize for people with large portfolios.
The facts
- Qualifying figure
- €46.7k
- Total landed cost
- No cost to apply. Value is 30% of gross salary paid free of tax and social security, capped by the WNT norm of EUR 262,000 (2026) — so a maximum of about EUR 78,600 of tax-free reimbursement a year
- Timeline
- 1–4 months — Joint employer/employee application to the Belastingdienst; apply within 4 months of starting work to get it backdated to day one
- Physical presence
- Must have lived more than 150km from the Dutch border for at least 16 of the 24 months before starting work
- Family
- employee only — the ruling attaches to the employment relationship, not the family
- Permanent residency
- n/a — a tax regime; residence comes from a separate permit
- Citizenship
- n/a
- Dual citizenship
- Not permitted — you would have to renounce
- Requirements
- recruited from abroad by a Dutch withholding agentlived more than 150km from the Dutch border for 16 of the 24 months before the first working dayspecific expertise scarce in the Dutch labour market, evidenced by the salary norm: EUR 46,660 taxable salary in 2026 (EUR 35,468 for under-30s with a qualifying master's)joint application to the Belastingdienst
- The partial non-resident taxpayer election ends on 31 December 2026 — this year. It let ruling holders be treated as non-resident for Box 2 and Box 3, keeping worldwide investment wealth outside the Dutch net. It was abolished from 2025 with transitional relief only for those using the ruling in the final pay period of 2023, and that transition expires in months. From 1 January 2027 every ruling holder is fully taxable as a Dutch resident on worldwide Box 1, 2 and 3 income. For a family with a nine-figure portfolio this dwarfs the 3-point cut.
- Box 3 taxes a deemed return, not your actual return. A portfolio that lost money still generates a tax charge. This is the most punitive feature of the Dutch system for asset-rich families and it has been the subject of years of Supreme Court litigation.
- The 27% cut from 2027 applies to post-2024 starters; pre-2024 starters keep 30%. Check the start date before accepting any number.
- Salary thresholds rise sharply and above inflation in 2027: EUR 50,436 general and EUR 38,388 for under-30 master's holders, against EUR 46,660 and EUR 35,468 in 2026. The 2027 figures are subject to final confirmation.
- Maximum 5 years, reduced by prior Dutch stays in the preceding 25 years.
- The Netherlands does not generally permit dual citizenship for naturalising adults — a serious constraint for anyone contemplating a Dutch passport.
- The effective date of the 27% measure has been described by the government itself as not yet final pending publication.