Tax Plan 2024: adjustments and reduction of the 30% ruling

Under the Tax Plan for 2024, the 30% ruling is scaled back as of the 1st of January 2024. The benefit of the 30% ruling will gradually decrease over its five-year term, transitioning ultimately into a 10% ruling. More precisely, for the first 20 months, the 30% exemption on the salary will remain. This will be followed by a reduction to 20% for the next 20 months, and finally, for the last 20 months, the exemption will be limited to 10% of the salary.

Employees that already hold the 30% ruling (i.e., granted in 2023 or earlier), will fall under the old regime (shortly stated – 60 months a 30% taxable benefit).

In addition to the gradual decrease of the 30% ruling into a 10% ruling, the partial foreign taxpayer status (‘partiële buitenlandse belastingplicht’) will be abolished as of the 1st of January 2025. Employees to whom the 30% ruling is granted in 2023 or earlier will fall under transitional law and can benefit of the partial foreign taxpayer status up to and including 2026.

Note that the Dutch Senate made a plea to the Dutch government to have a critical look at the economic consequences of the changes made to the 30% ruling. Should an evaluation conclude that there will be a negative economic impact, the Dutch Senate suggests having an alternative amendment for the 30% ruling legislation in the Tax Plan for 2025.

We will keep you informed.

Questions?

Please contact our colleagues of the Employment & Compensation Tax Team.