From 1 January 2027 a Dutch employer can pay a qualifying expat at most 27 percent of salary tax-free, down from 30 percent. Employees whose ruling applied by the last pay period of 2023 keep 30 percent for their whole term. Employees who first used the scheme from 2025 also face a higher salary norm.
What changes on 1 January 2027
The rate is written into the statute. Article 31a of the Wage Tax Act 1964, in the version in force from 1 January 2027, treats reimbursements for an incoming employee as extraterritorial costs "tot ten hoogste 27%" of the designated salary, for at most five years. The same article limits the allowance per employee to 27 percent of the maximum pay under the Dutch public sector pay cap act (WNT).
The reduction was added to the Tax Plan 2025 by the second memorandum of amendment of 29 October 2024, which replaced the 30, 20, 10 percent step-down introduced for 2024 with a flat rate: 30 percent in 2025 and 2026, then 27 percent. The paper applies the same 27 percent to outgoing employees posted abroad by a Dutch employer, with no exception for postings that began before 2024.
Who keeps 30 percent
The memorandum sets out three groups by the year the ruling was first applied:
- Applied by 31 December 2023 · 30 percent in 2025 and 2026 · 30 percent from 2027 · old salary norm throughout
- First applied in 2024 · 30 percent in 2025 and 2026 · 27 percent from 2027 · old salary norm kept
- First applied from 1 January 2025 · 30 percent in 2025 and 2026 · 27 percent from 2027 · new salary norm
The protected group loses that protection after a break. The memorandum states that an employee who used the ruling before 2024 but whose employment is interrupted after 31 December 2023 falls under the new rules on return to the Netherlands.
The new salary norm
The current norm sits in article 10eb of the Wage Tax Implementing Decree 1965: taxable salary above €48,013 a year, or above €36,497 for an employee under 30 with a Dutch master's degree or a foreign equivalent. Belastingdienst publishes the same two figures for 2026. Researchers at designated institutions and doctors training as specialists need not meet any salary norm.
For 2027 the memorandum raises the norms to €50,436 and €38,338, both in 2024 prices, and states that they will be indexed to 2027 with the table correction factor. The €50,436 is the highly skilled migrant salary of €69,090 a year less 27 percent. As of 26 September 2026 the consolidated decree on wetten.overheid.nl carries no 2027 version, so the indexed 2027 amounts are not yet published. Two government portals, business.gov.nl and Ondernemersplein, print the under-30 figure as €38,388; the parliamentary paper, whose own footnote arithmetic gives €38,338, is the controlling text.
What it costs in euros
The allowance is at most 30 percent of salary including the allowance, according to Belastingdienst. On a package of €100,000 including the allowance, that is €30,000 tax-free in 2026 and €27,000 in 2027 for an employee who started in 2024 or later. The €3,000 difference becomes taxable salary.
At the top the cap binds. Belastingdienst states that in 2026 the tax-free allowance is at most €78,600, reached at a salary of €262,000 or more. Applying 27 percent to the same €262,000 gives €70,740; the real 2027 cap depends on the 2027 WNT maximum, which is set separately.
The second 2027 cliff: partial non-resident status
Partial foreign tax liability let an expat on the ruling be treated as a non-resident for box 2 (substantial shareholdings) and box 3 (savings and investments) while living in the Netherlands. Belastingdienst states that it can no longer be chosen from 1 January 2025, and that anyone who used the expat scheme before 2024 can keep it "tot en met 2026". From the 2027 tax year that group reports worldwide savings, investments and substantial holdings in box 2 and box 3. For someone with a large portfolio abroad this can outweigh the 27 percent change itself.
What did not change
- Maximum term · five years, reduced by earlier Dutch stays, per Belastingdienst
- Distance test · more than 16 of the 24 months before starting spent more than 150 km in a straight line from the Dutch border
- Application · filed within four months of the employee's first working day, per business.gov.nl; a decision follows within 8 weeks
- Employment · the scheme applies to employees only, not the self-employed
For comparison, for how southern Europe prices new residents, see Portugal's IFICI regime and Italy's flat tax against Greece's; for the cost of leaving again, see exit taxes in the Netherlands and four neighbours.
Heed's reading: the 3 point cut is visible on every payslip, but the larger 2027 change for pre-2024 arrivals is the end of partial non-resident status, which moves foreign wealth into Dutch box 3 from the first day of the year.
Heed monitors international tax law changes across every jurisdiction we track and sends personalised alerts before they affect your situation. The rules above sit in the Netherlands country guide, and the residence questions they raise are covered under tax residency tracking.