Dutch government revises 30%-facility with transition to a 27%-facility from 2027

The Dutch government has announced that the 30%-facility (a tax incentive for employees who are seconded or hired from abroad to work in the Netherlands) will transition to a 27%-facility effective from 1 January 2027.

Detail of the changes

Initially, the 30%-facility was set to gradually decrease to a 10% ruling over five years starting from 1 January 2024 (see our earlier Insight). However, this plan has been revised, and the 30%-facility will now transition to a 27%-facility effective from 1 January 2027.

In the years 2024, 2025 and 2026, a 30% rate will apply for all employees utilising the facility.

The salary requirement, which is one of the specific conditions for the facility, will be increased from €46,107 to €50,436 (2024 indexed). For employees under 30 years with a master's degree, the salary requirement will be increased from €35,048 to €38,338 (2024 indexed).

Although the Dutch government's announcement does not include an exact date, we expect this increased requirement to take effect starting from 1 January 2027, based on related documents.

The transitional laws will be respected for employees who were granted a 30% ruling before 2024. For them, a rate of 30% and the old (indexed) salary norms will apply until the end of the facility term.

Impact on rulings

These changes mean the following for rulings granted or to be granted:

• prior to 1 January 2024: The 30% rulings will be respected until the end of term, allowing a maximum of 60 months at 30%.
• between 1 January 2024 and the end of 2026: The 30% rate will apply for the years 2024, 2025 and 2026, and then it will be reduced to 27% starting from 1 January 2027.
• after 1 January 2027: The rate will be set at 27% for a duration of 60 months (five years).

Please get in touch with your usual Osborne Clarke contact or one of the experts below if you have any queries or would like to discuss this further.