Effective January 1, 2024, a number of important changes were made to the 30% ruling. In brief, these are as follows. Transitional law has been created for existing cases.
Capping
As of January 1, 2024, the 30% allowance is capped at the WNT/Balkenende nprm (for the year 2024: EUR 233,000). As a result, the maximum 30% allowance is EUR 69,900 in 2024. If the 30% ruling only applies for part of the year, then the maximum amount is applied pro rata.
Note: The WNT nprm is adjusted annually.
This change had already been introduced at the end of 2022. At the time, transitional law was created for employees for whom the 30% ruling had been applied over the last pay period of 2022. For this group of employees, the cap will be applicable until January 1, 2026.
30/20/10% rule (austerity)
As of January 1, 2024, the percentage of the tax-free allowance (30% ruling) will be gradually reduced during the duration of the 30% ruling. The first 20 months are entitled to a maximum tax-free allowance of 30%, the 20 months after that a maximum of 20% and the remaining 20 months only a maximum of 10%.
- Month 1 – 20 tax-free allowance up to 30%
- Month 21 – 40 tax-free allowance up to 20%
- Month 41 – 60 tax-free allowance up to 10%
Transitional law was created for employees for whom the 30% ruling was applied no later than in the last payroll period of 2023 (the period ending December 31, 2023). In this regard, the Knowledge Group of the Dutch tax authorities is of the opinion that for this transitional rule, it is sufficient that the 30% ruling was applied in any period before January 1, 2024. The employee does not have to have held the 30% grant letter before December 31, 2023.
Abolishment of partial foreign tax liability (austerity)
As of January 1, 2025, the option for employees with the 30% ruling to opt for foreign partial tax liability in their income tax returns is abolished. This means that for Box 2 (income from substantial interest) and Box 3 (income from savings and investments), these employees are treated as residents of the Netherlands. They are then taxed on their worldwide income in these boxes instead of only specific Dutch sources. For employees with US citizenship or US Green Card holders, this additionally means that they will also be taxed on their non-Dutch working days (in Box 1).
Transitional law has been created for employees for whom the 30% ruling was applied in the last pay period of 2023 (the period ending December 31, 2023). For this group of workers, this measure does not take effect until January 1, 2027.
Correction/revoking of 30% grant letter
Effective January 1, 2024, the law includes a possibility for the correction or revoking of a 30% ruling grant letter. Before that, revoking was not possible and correction was limited.
See also “What if the 30% ruling was issued incorrectly by the Inland Revenue?”
