In 2024, the 2025 Tax Plan confirmed further adjustments to the 30%-ruling. From 2027, the maximum tax-free allowance under the 30%-ruling will be 27% instead of 30%.
Additionally, the option for partial non-domestic tax status is no longer from 1 January 2025. However, for employees who were already eligible for the 30%-ruling at the end of 2023, a transitional arrangement applies: they may still opt for partial non-domestic taxation until the end of 2026.
As in previous years, the 30%-ruling remains capped at a certain income level, known as the WNT norm (also referred to as the Balkenende norm). For 2025, this cap is set at €246,000 on an annual basis, and it will increase to €262,000 in 2026. A transitional arrangement applies for incoming employees for whom the 30%-ruling was applied in the last pay period (December) of 2022; for these employees, the income cap will only take effect from 1 January 2026.
The following deductions are available in the 2024 Income Tax return to reduce your taxable income:
mortgage interest of your first residence (owner-occupied home)
life annuity premiums (if deposited before 1st July 2024)
non-reimbursed health care expenses (including medical assistance, prescribed medication and travel expenses for hospital visits)
financial obligations to ex-spouse i.e. in the form of alimony
gifts or donations to recognized charities (refer to the ANBI list)
travel expenses for regular commuting by public transport
weekend expenses for taking care of disabled relatives
Please note that for some of the tax deductions a threshold or other conditions may apply. The expenses may therefore not be fully deductible. If you incurred expenses that may qualify, please do not hesitate to contact us.
The advantageous 30% ruling is getting harder to obtain! Read more here.
Restrictions
Last year, it was abruptly decided that the 30%-ruling was to be restricted. The maximum tax-exempt reimbursement of 30% would no longer apply for up to 60 months; instead, after every 20 months, the reimbursement would decrease by 10%. So, it would go from 30% to 20%, and eventually down to 10% for the last 20 months. This restriction was immediately met with a lot of criticism; it was seen as disavantageous to the Netherlands’ business and investment climate and would make for too much administrative hassle. In 2024, the 30% ruling was set to be evaluated again, and there were already suggestions that the restriction might be reversed. And that is exactly what happened in the Dutch Tax Plan 2025!
In the 2025 Tax Plans, the previously implemented restriction is being revoked, but, unfortunately, the 30% ruling will be limited in another way which is described below.
The 27% ruling
The maximum tax-free reimbursement of 30% will be reduced to 27% starting as of 2027.
In addition, from 2027 onwards, the income threshold for the 30%-ruling will be raised from €46,107 to €50,436. For employees under 30 years old with a master’s degree that are making use of the 30%-ruling, the income threshold will increase from €35,048 to €38,388. This is a significant increase, which will be indexed annually. In addition there is no longer an option to choose for partial non-domestic taxation from 2025 onwards.
These measures will result in fewer expats qualifying for the ruling and a decrease in the tax-exempt reimbursement. For all expats who already qualified for the 30% ruling before January 1, 2024, the maximum tax-exempt reimbursement will remain at 30% for the entire duration and they will be able to opt for partial non-domestic taxation until 2026.
Suurmond Tax consultants will, as before, be at your side to help you gain the 30% ruling – although there are a lot more restrictions than there used to be, of course. We have obtained favourable results in many different situations.
Or do you already have the 30%-ruling and is it ending soon? Then contact us and we can advise as to the consequences and tax optimisation possibilities!
As you may have heard in the press, the Supreme Court ruled on 24 December 2021 that the box 3 tax based on a fictitious return on investment in 2017 and 2018 is disproportionately high and is therefore in violation of the European Convention for the Protection of Human Rights (ECHR). The Supreme Court ruled that a relatively heavy financial burden is attached to the choice not to go into risky investment of assets.
Furthermore, the fixed asset mix introduced in 2017 has a discriminatory effect on those who have had bad luck with their investments and nevertheless are taxed relatively heavily. That is why the Supreme Court offers legal redress in the sense that for the years 2017 and 2018 the tax should be based only on the actual return on investment. After the negative court decisions for earlier years, this finally means a positive outcome for the tax payer with saving accounts and hardly any interest.
Decision in mass appeal procedure
At the beginning of February, the Tax Office published the collective decision in the mass appeal procedures against the box-3 tax for 2017 to 2020. All 200,000 appeals have been allowed. This does not yet mean that the participants in the mass appeal procedures now know how much they will get back and when. Neither is anything known about possible compensation for other taxpayers who did not appeal against the box-3 levy. The cabinet has promised to provide a substantive response no later than 1 May 2022 on how restoration of rights can be offered over the past few years. For most situations involving a substantial box 3 tax, we have already raised appeals over the past few years. Further action is only meaningful after we know more about the promised response from the Tax Authorities.
New box 3 levy
According to the cabinet, a box 3 levy based on the actual return on investment cannot come into effect until 2025. However, emergency legislation to adjust the box 3 levy is currently being worked on, which should provide a solution for the intervening years. This could include, for example, fictitious interest rates that are more in line with the actual returns and based on the actual composition of the assets. The cabinet is planning on sending a memorandum of direction for the recovery operation to the parliament before 1 April 2022.
Moreover, it is clear that a new system will certainly not lead to advantages for all taxpayers. Taxing actual returns can also mean taxing capital gains from securities and real estate, which have not been taxed as such until now. Besides, a number of parties state that the coverage for the measures should come from the same category of taxpayers.
Future assessments and tax returns
The ruling of the Supreme Court has consequences for 2021 and later years too. No final assessments are currently sent to taxpayers with box-3 capital. An exception will only be made if prescription is imminent or if there is an interest in the taxpayer. As soon as it is clear what the recovery will look like, these assessments will be issued. Taxpayers will be informed about this.
The Tax Office asks taxpayers to pay the provisional tax assessment 2022. They are also asked to simply submit the 2021 tax return, stating the box-3 capital as before. Possible compensation will be worked out later. Taxpayers with box-3 assets will probably receive their assessment for 2021 after 1 July 2022, even if they have submitted their 2021 tax return before 1 April.
For many expats the 30% ruling may cease by the end of this year as the transition period for those originally with an 8 year duration is discontinued. It is important to check the situation and possibilities to minimise the tax consequences.
Is your 30% ruling ending? Do you have worldwide assets? Contact us now to see what your tax saving possibilities are.
30% ruling end
Prior to 2019, the 30% ruling period was 8 years. As of January 2019 the period was shortened to 5 years. A two-year transition period was implemented lasting until January 1st 2021. This means that:
For anyone granted the ruling between January 1st 2011 and January 1st 2013 the 8-years still count, ending between January 1st 2019 and January 1st 2021;
those granted the ruling between January 1st 2013 and January 1st 2016 will be able to receive the allowance until 31 December 2020, giving them up to an additional two years following the extension;
anyone granted the ruling after January 1st 2016 will be eligible for the 30% ruling benefit for 5 years
30% ruling is ending as of January 2021
This means that for many international workers their 30 % ruling is ending as of January 2021. If you are one of them, it is important to be well prepared for the consequences. Not only will your take-home salary become lower, but you will also need to start thinking about your wealth and what this will mean for your tax return.
Without the 30% ruling, you can no longer opt to be considered a partial non-domestic taxpayer. In other words, you will be treated as a full resident tax payer and you will need to state your worldwide assets in your Dutch tax return. It is important that you are well prepared for this change and seek tax advice.
“Take this example from an international from Greece who’s 30% ruling period will end January 1st 2021. From then on she will no longer be able to opt for non domestic taxpayer; that means she becomes taxable in the Netherlands for her worldwide assets. Since she has savings in Greece she will have to pay box-3 tax in the Netherlands. Our tax consultants can help her structure things in such a way to reduce her tax liability. One of the possibilities we would be looking at is to reduce her box 3 tax liability by using her savings to repay part of her Dutch morgage. Although in that case she would receive less mortgage relief it would als lead to reduction of payable mortgage interest. And she would have less savings and thus as a reduction in box 3 taxation.”
Tax on assets and foreign real estate
This year the threshold per individual is € 30,846 before the asset tax starts. Your assets of between €30,846 and € 103,643 are taxed at 0.54%; assets of between €103,643 and €1,036,418 will be taxed at 1.27%; and anything over that at 1.6%. Given these fixed amounts of tax are unrelated to the actual income your assets generate, the higher your income, the more tax efficient you are. But they are still amounts which have to be found and paid.
You also need to include foreign real estate in your tax return and request a deduction for double taxation. In most Dutch tax treaties, the taxation of real estate is always allocated to the country where the property is located.
Avoid a large fine
It is really important to be honest and fill in your tax form correctly. The Dutch tax office is particularly hot on foreign bank accounts, and you can be fined up to 300% of the unpaid tax if you forget to mention them.’
If you would like to find out more about maximising your tax efficiency and decreasing your risk of fines, please feel free to contact us.
The Tax and Customs Administration has published the collective decision in the massive objection procedures against the box-3 tax for 2017 to 2020. All 200,000 objections have been declared well-founded. This does not mean that the participants in the mass appeal procedures now know how much they will get back and when.
There is also nothing known about possible compensation for other taxpayers who have paid too much box-3 levy. According to the cabinet, a box-3 levy based on the actual return cannot come into effect until 2025. However, urgent legislation is currently being worked on, which should provide a solution for the intervening years.
The emergency legislation makes adjustments to the existing box-3 legislation. The cabinet undertakes to send a memorandum of direction for the recovery operation to the House of Representatives before 1 April 2022. The left-wing opposition parties have already announced a private member’s bill that is based on a progressive levy on assets minus debts with a tax-free allowance of € 100,000 per person. The owner-occupied home remains in box 1 and substantial interest shares in box 2. The rate increases from 1% to 500,000 to 5% above € 5 million in taxable capital.
Tax assessments and tax return 2021
The ruling of the Supreme Court also has consequences for 2021 and later years. No final assessments are currently sent to taxpayers with box-3 capital. An exception is only made if there is a threat of prescription or if there is an interest in the taxpayer. As soon as it is clear what the recovery will look like, these attacks will be reinstated. Taxpayers will be informed about this.
The Tax and Customs Administration asks taxpayers to pay the provisional tax assessment 2022, pending further decisions. They are also asked to simply submit the 2021 tax return, stating the box-3 capital. Taxpayers with box-3 capital will probably receive their 2021 assessment later than 1 July 2022, even if they submitted their 2021 tax return before 8 April.
For many expats the 30% ruling may cease by the end of this year as the transition period for those originally with an 8 year duration is discontinued. It is important to check the situation and possibilities to minimise the tax consequences.
Is your 30% ruling ending? Do you have worldwide assets? Contact us now to see what your tax saving possibilities are.
30% ruling end
Prior to 2019, the 30% ruling period was 8 years. As of January 2019 the period was shortened to 5 years. A two-year transition period was implemented lasting until January 1st 2021. This means that:
For anyone granted the ruling between January 1st 2011 and January 1st 2013 the 8-years still count, ending between January 1st 2019 and January 1st 2021;
those granted the ruling between January 1st 2013 and January 1st 2016 will be able to receive the allowance until 31 December 2020, giving them up to an additional two years following the extension;
anyone granted the ruling after January 1st 2016 will be eligible for the 30% ruling benefit for 5 years
30% ruling is ending as of January 2021
This means that for many international workers their 30 % ruling is ending as of January 2021. If you are one of them, it is important to be well prepared for the consequences. Not only will your take-home salary become lower, but you will also need to start thinking about your wealth and what this will mean for your tax return.
Without the 30% ruling, you can no longer opt to be considered a partial non-domestic taxpayer. In other words, you will be treated as a full resident tax payer and you will need to state your worldwide assets in your Dutch tax return. It is important that you are well prepared for this change and seek tax advice.
“Take this example from an international from Greece who’s 30% ruling period will end January 1st 2021. From then on she will no longer be able to opt for non domestic taxpayer; that means she becomes taxable in the Netherlands for her worldwide assets. Since she has savings in Greece she will have to pay box-3 tax in the Netherlands. Our tax consultants can help her structure things in such a way to reduce her tax liability. One of the possibilities we would be looking at is to reduce her box 3 tax liability by using her savings to repay part of her Dutch morgage. Although in that case she would receive less mortgage relief it would als lead to reduction of payable mortgage interest. And she would have less savings and thus as a reduction in box 3 taxation.”
Tax on assets and foreign real estate
This year the threshold per individual is € 30,846 before the asset tax starts. Your assets of between €30,846 and € 103,643 are taxed at 0.54%; assets of between €103,643 and €1,036,418 will be taxed at 1.27%; and anything over that at 1.6%. Given these fixed amounts of tax are unrelated to the actual income your assets generate, the higher your income, the more tax efficient you are. But they are still amounts which have to be found and paid.
You also need to include foreign real estate in your tax return and request a deduction for double taxation. In most Dutch tax treaties, the taxation of real estate is always allocated to the country where the property is located.
Avoid a large fine
It is really important to be honest and fill in your tax form correctly. The Dutch tax office is particularly hot on foreign bank accounts, and you can be fined up to 300% of the unpaid tax if you forget to mention them.’
If you would like to find out more about maximising your tax efficiency and decreasing your risk of fines, please feel free to contact Suurmond Tax Consultants www.suurmond-taxconsultants.com .
The last time the 30 percent ruling in the Netherlands was thoroughly revised was in 2012. The main changes considered the maximum period of 8 years instead of 10 years.
Also expats have to have lived further than 150 kilometers away from the Dutch border during more than 16 months before their employment in Holland to qualify for the 30 percent ruling. Besides these alterations there is the change in the criterion. Before it was called the specific knowledge criterion, now it is basically a salary criterion, indicating that employees from abroad that have specific knowledge earn more. An exeption is made for younger persons with a master degree and those that receive their PhD in the Netherlands.
The past years these changes have raised many questions, especially the 150 kilometer rule. Especially if someone has had to move more than 150 kilometers it can be confusing if the application is denied. The Tax authorities are strict in applying the rule, 1 kilometer can make the difference. It could also be that you have moved 280 kilometers from Cologne (Köln) to The Hague, but do not apply for the 30 percent ruling because Cologne is less then 150 kilometers from the Dutch border.
The fact that you have to have lived abroad for 16 months raises a lot of questions. What if you have worked in a different job before in which the 30% ruling applied? What if you were travelling and it is not sure where your center of life was? Answers to these questions are sometimes hard to find and qualified tax advice is required.
Salary criterion
With the salary criterion it is crucial that the qualifying salary of € 36.705,– or more (in 2015) is the taxable salary after the 30%-ruling has been applied. Make sure your employer or payroll agency applies the 30%-ruling correctly. We offer second opinion advice when your apllication is denied or when you have doubts about the procedure being correct or not. You cab also contact us if you want to know more about the 16 month period that you have to have lived abroad, since this often raises a lot of questions.
In case of unemployment
Last but not least we want to highlight that, if unfortunately this situation occurs, you need to make sure that you are not unemployed for longer than 3 months in between jobs. If you exceed this period you will loose your eligibility for the 30% ruling in the new job.
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