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T +31 20 535 4567

info@atlas.tax

2024-05-16

Svalner Atlas Group
– The new premier advisory group

Svalner, Atlas and Alder are joining forces forming the new premier advisory group – Svalner Atlas Group.

The Group has more than 260+ skilled professionals operating from Stockholm, Amsterdam, Helsinki, Gothenburg and Turku offices. This newly formed powerhouse will become a leading independent advisory group in the Nordics and Benelux.

Together we are the go-to destination for top-tier advisory in tax, transaction services and related services. Join us on this venture, as we set new standards in advisory excellence.

Vision

Our vision is to be the first choice for clients seeking high-end advisory
in tax, transaction services and related services.

Visit the current members of the
Svalner Atlas Group

www.svalner.se
www.atlas.tax
www.alder.fi

New Rules and Transitional Law for the 30% Ruling

The Dutch tax authorities issued as so-called kennisgroepstandpunt (knowledge group position of the Dutch tax authorities) about changes to the 30%-ruling, applicable in 2023 and 2024. Per the beginning of 2023 a salary cap was introduced and per 2024 the 30% ruling has been transitioned in a 30%/20%/10% ruling. For rulings already obtained prior to the changes, transitional law applies.

It was unclear whether a 30% ruling that was applied for in time, but granted retroactively can also fall under transitional law. The tax authorities seemed to have the view that retroactive application of the ruling was not sufficient for the transitional law. This new kennisgroepstandpunt clearly ends this discussion by explicitly stating that 30% rulings granted retroactively and applied in payroll retroactively (by way of filing a payroll correction) also fall under transitional law.

In practice this means that:

  1. An employee holding the 30% ruling may benefit from an uncapped 30% ruling until 2026 instead of 2024, if the ruling was applied at least in the December 2022 payroll, which now also includes the situation that the ruling is obtained in 2023, but applied with retroactive effect in 2022.
  2. An employee holding the 30% ruling may benefit from a 30% ruling instead of a 30%/20%/10% ruling, if the ruling was applied at least in the December 2023 payroll, which now also includes the situation that the ruling is obtained in 2024, but applied with retroactive effect in 2023.

Questions?

If you have any questions with regard to the 30%-ruling, please contact our colleagues of our Employment & Compensation tax team.

Yvonne Bakker

Counsel

Maarten de Vries

Associate

Peter Karman

Counsel

Audrey Mol

Associate
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