The 30% ruling in 2026: what stays, what changes from 2027
The 30% ruling has been reshaped several times in short order. The steep 30/20/10 phase-down that was legislated for 2024 was rolled back before it ever took effect. Here is where the rules actually stand today, and how to model total compensation without over- or under-promising the candidate.
執筆 Joost Hubregtse, Director, ICS Staffing & Payroll
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Where the rate stands today
The 30/20/10 tranche schedule was reversed in the Belastingplan 2025. For rulings granted from 2024 onward, the reimbursement stays at 30% for the full term through 2026, and steps down to a flat 27% from 1 January 2027 for the remainder of the five-year term. There is no 20% or 10% tranche.
Rulings issued in 2023 or earlier keep the full 30% for their whole five-year term under grandfathering, and keep the partial non-resident election in box 2 and box 3 until the end of 2026.
Salary norm and look-back
The minimum taxable salary norm is indexed annually. The 24-month look-back rule and the 150 km distance-from-border rule were not changed in the reform - eligibility logic is unchanged, only the percentage that applies from 2027 is lower.
We confirm the exact indexed norm per case before issuing a contract, and separately check the reduced norm that applies to under-30s with a qualifying master's degree.
Compensation modelling
To keep net pay flat when the rate steps from 30% to 27% in 2027, plan the gross uplift at the year boundary and write it into the offer letter. The step is smaller than the original 30/20/10 schedule would have been, but it is not zero.
For senior hires already at or above the cap, the WNT-linked cap on the salary base over which the 30% (or 27%) applies is what bites first. That cap has applied since 1 January 2024; from 2026 the transitional relief has fallen away and the cap sits at EUR 262,000. We model the rate step and the cap together before any offer goes out.
Partial non-resident status
The abolition of the partial non-resident election in box 2 and box 3 is now in force for new rulings; only 2023 rulings keep the option, and only until the end of 2026. For new hires with material investment portfolios, this is the change that usually matters more than the headline percentage.
We routinely see candidates arrive expecting box 3 to be sheltered for the full ruling term. That assumption is wrong from 2027 onwards and it materially changes the net-of-tax calculation on a Dutch package versus an offer in Dublin, Lisbon or Berlin.
What to renegotiate in 2026
Open-ended contracts written before the 2025 reversal often reference an assumed 30/20/10 step-down that no longer exists. Update the compensation clause to reflect the actual 30% through 2026, 27% from 2027 schedule and remove any tranche language that never came into force.
Bonus and RSU vesting that lands in 2027 or later is the part finance teams routinely miscalculate. Model the cash component net of the 27% rate for anything vesting after 1 January 2027, not the 30% rate at hire date.
Pension contributions over the reimbursed portion are not pensionable by default. If you offer a competitive pension match, decide explicitly whether the match is calculated on the full gross or only the taxable base, and write that choice into the policy before the first contribution lands.