If you currently benefit from the Dutch Expat Scheme (formerly known as the 30% ruling), it is worth taking a closer look at the changes that will take effect in 2027.
The Dutch government has introduced several changes that may affect the amount of tax-free compensation you can receive, the salary requirement that applies to you, and the tax treatment of your assets and investments.
The impact on your situation depends largely on one key question:
For some employees, transitional rules apply. Others will be fully subject to the new regime starting in 2027. In addition, the applicable salary threshold and the abolition of the partial non-resident taxpayer status can also affect your position.
In this article, we explain what is changing, which salary requirements apply, and what these changes could mean for your net income.
The most widely discussed change is that the maximum tax-free reimbursement under the Expat Scheme will, in many cases, decrease from 30% to 27% of qualifying employment income starting January 1, 2027.
In addition:
New and higher salary requirements will apply to certain employees.
The option to benefit from the partial non-resident taxpayer status will disappear completely.
Transitional rules will continue to apply to specific groups of employees.
However, not every employee will be affected in the same way.
The consequences depend on when the scheme was first applied. If the Expat Scheme was previously applied by another employer, the original application date is relevant when determining which rules apply to your situation.
|
First application of the Expat scheme |
Maximum tax-free reimbursement from 2027 |
Salary requirement from 2027 |
Partial non-resident taxpayer status |
|
Applied on or before 31 December 2023 |
Maximum 30% |
Transitional rules apply |
Available until the end of 2026 |
|
Applied during 2024 |
Maximum 27% |
Transitional rules apply |
Ends in 2026 |
|
Applied from 1 January 2025 onwards |
Maximum 27% |
New salary requirements |
Not available |
Let's look at each situation in more detail.
Employees whose Expat Scheme was already in place before January 1, 2024, benefit from the most extensive transitional arrangements.
If this applies to you, you can continue to receive a maximum tax-free reimbursement of 30% throughout the remaining validity period of your scheme. The reduction to 27% does not apply to your situation.
You also continue to fall under the salary threshold that applies to your existing ruling, including annual indexation.
In addition, you may still benefit from the partial non-resident taxpayer status for the 2025 and 2026 tax years. However, this facility will disappear completely starting with the 2027 tax year.
If the Expat Scheme was first applied to your salary during 2024, a combination of transitional rules and new legislation applies.
Until the end of 2026, the maximum tax-free reimbursement remains 30%.
Starting January 1, 2027, the maximum reimbursement decreases to 27%.
However, transitional rules continue to apply to the salary requirement. This means that you remain subject to the existing indexed salary thresholds during the remaining validity period of your ruling. You do not need to meet the higher salary thresholds introduced for new cases from 2025 onward.
Like all other employees, you will no longer be able to use the partial non-resident taxpayer status starting with the 2027 tax year.
Employees who first qualify for the Expat Scheme from 2025 onward will be fully subject to the new regime starting in 2027.
This means:
The maximum tax-free reimbursement is limited to 27%.
The new and higher salary requirements apply.
The partial non-resident taxpayer status is no longer available.
This group will experience the most significant impact.
To remain eligible for the Expat Scheme, you must continuously meet a minimum salary requirement throughout the duration of the ruling. If your taxable salary falls below the applicable threshold, the Expat Scheme may no longer be available. This requirement is known as the specific expertise requirement.
Three scenarios are relevant:
The standard salary requirement.
The reduced salary requirement for employees under 30 with a qualifying master's degree.
Transitional salary requirements for existing beneficiaries.
Employees whose Expat Scheme started on or after January 1, 2025, must satisfy the following salary requirements in 2027:
Standard salary requirement: EUR 53,887 per year.
Reduced salary requirement for employees under 30 with a qualifying master's degree: EUR 40,961 per year.
Please note that these 2027 salary thresholds are provisional and subject to final confirmation.
These amounts relate to taxable salary excluding the tax-free reimbursement and may be adjusted through future indexation.
A lower salary threshold applies if you:
Are younger than 30 years old; and
Hold a Dutch master's degree or a foreign master's degree that is recognized as equivalent in the Netherlands.
The purpose of this exception is to help attract international talent at the start of their careers. If you fall within this category and are subject to the post-2025 regime, the salary requirement for 2027 is EUR 40,961 per year.
Please note that once you turn 30, the regular salary threshold must be met.
Not everyone will be subject to the new salary requirements. Employees whose Expat Scheme was first applied no later than 2024 continue to benefit from transitional arrangements regarding the salary requirement.
For 2027, the indexed salary thresholds under the transitional regime are:
Standard salary requirement: EUR 49,261 per year.
Reduced salary requirement for qualifying employees under 30: EUR 37,446 per year.
|
Situation |
Standard salary requirement |
Reduced salary requirement (under 30 with qualifying master's degree) |
|
Transitional regime (first application no later than 2024) |
EUR 49,261 |
EUR 37,446 |
|
New regime (first application from 2025 onwards) |
EUR 53,887 |
EUR 40,961 |
The salary requirements relate to taxable salary excluding the tax-free reimbursement under the Expat Scheme. The amounts shown for 2027 are provisional.
One change that receives less attention but can have a significant impact for some international employees is the abolition of the partial non-resident taxpayer status.
This arrangement allowed eligible employees to be treated as non-resident taxpayers for certain Dutch tax purposes, particularly regarding Box 2 (substantial shareholdings) and Box 3 (savings and investments). In practice, certain foreign assets could remain outside the Dutch tax base.
For new cases, this facility was abolished starting January 1, 2025.
Employees who already benefited from the Expat Scheme before 2024 may still rely on transitional provisions until the end of the 2026 tax year.
Starting with the 2027 tax year, the partial non-resident taxpayer status will no longer be available to anyone.
If you own foreign investments, hold a substantial interest in a company, or have other international tax considerations, this change may be particularly relevant.
The 2027 changes do not automatically mean that every expat will receive a lower benefit.
The actual impact depends on:
The date your Expat Scheme was first applied.
Your salary level.
The content of your ruling.
How your employer applies the scheme.
Whether transitional arrangements apply to your situation.
To avoid surprises, it is advisable to review:
When the Expat Scheme was first applied to your salary.
Which salary threshold applies to you.
Whether you qualify for transitional arrangements.
Whether you currently benefit from the partial non-resident taxpayer status.
The expected impact on your net income starting in 2027.
Although much of the discussion focuses on the reduction from 30% to 27%, for many employees the new salary requirements and the abolition of the partial non-resident taxpayer status may be equally important.
If you qualify for transitional arrangements, the impact may be relatively limited. If your Expat Scheme started from 2025 onward, you will generally be affected by both the lower reimbursement percentage and the higher salary thresholds.
It is therefore advisable to review your position well before 2027 and discuss the potential impact with your employer, payroll specialist, or tax advisor.
The impact of the 2027 changes depends on your individual circumstances. Our Exterus specialists can help you understand which rules apply to your situation and what the changes may mean for you.
Feel free to contact us if you have questions about your Expat Scheme.
Disclaimer: This article provides general information only and should not be regarded as personal tax advice. The application of the Dutch Expat Scheme depends on your individual circumstances, salary, employer, and official ruling.