Tax Plan 2025

Tax Plan 2025: what are the consequences for the 30% ruling?

Sander Agterhof
By:
30% ruling becomes 27% per 2027
In the last years we had multiple changes regarding the benefits of the 30% ruling. Per 14 November 2024 the announced changes have been adapted by the House of Representatives (“Tweede Kamer”) as part of the Tax Plan 2025. The Tax Plan 2025 is now subject to the final approval of the Senate (“Eerste Kamer”) which will take place in December.

We are happy to share an overview of the changes regarding the 30% ruling as mentioned in the Tax Plan 2025. 

Previous changes

In the last years we had the following changes:

  1. The introduction of the “salary cap” has been adopted per 1 January 2023, transitional rules apply. See more details in our previous article.
  2. The introduction of the 30/20/10% rule has been adopted in the tax rules per 1 January 2024, transitional rules apply. With this rule the tax free percentage is reduced every 20 months with 10%. So eventually, employees will a receive a maximum of up to 10% tax-free allowance instead of 30%.
  3. The cancellation of the partial non-residency treatment has been adopted in the tax rules per 1 January 2024, transitional rules apply. Employees who receive the 30% ruling have the possibility to choose for the partial non-residency treatment. These employees have a very limited (or no) obligation to report and pay income tax over their private investment income (Box 2 and Box 3) in the Netherlands during the period the 30% ruling is applicable (in principle five years).

2025 Tax Plan amendments regarding the 30% ruling

Based on the adapted Tax Plan 2025 we now know that the announced 30/20/10% rule (2. mentioned above) will be cancelled. The other two changes mentioned above (1. and 3.) will remain applicable. 

In addition, the percentage of the tax-free allowance will be reduced to 27% per 1 January 2027 and the salary level to qualify for the 30% ruling will be increased. Transitional rules will be applicable for employees who had the 30% ruling before 2024, or at least started their employment before January 1st 2025. These employees will keep a tax-free allowance of up to 30% during the total period of the 30% ruling. In addition, the salary level remains the same, although it will be subject to annual indexation. 

This means that for the employees who received the 30% ruling in 2024 or later, limited transitional rules will apply. These employees will receive a maximum of 27% tax-free allowance as of 2027. In addition, the announced higher salary norm will be applicable for employees who will receive the 30% ruling as of 1 January 2025. As such, a part of the group that received the 30% ruling in 2025 or will potentially lose the 30%/27% ruling if they no longer meet the new salary criteria in 2027 or onwards.

Please find below an overview of the adapted transitional rules:

Application of the 30% ruling
2025/2026
From 2027
Before 01-01-2024
30%
EUR 46,107 / 35,048*
30%
Indexation of current salary level
In 2024
30%
EUR 46,107 / 35,048*
27%
Indexation of current salary level
As of 01-01-2025
30%
EUR 46,107 / 35,048*
27%
New salary criteria 
EUR 50,436 / 38,338*

*All figures are subject to indication. The figures mentioned relate to 2024.

To be continued!

Sander Agterhof
Sander Agterhof , Partner
Please note that the Senate still has to vote for the Tax Plan. We will keep you updated on further developments. Meanwhile, if you have any questions regarding the 30% ruling please feel free to contact me.