Results of the evaluation of the 30% ruling – and what’s next?

At the end of 2023, the House of Representatives adopted two significant changes regarding the 30% ruling. It was decided that new users of the scheme would no longer be able to receive up to 30% of their salary tax-free for a maximum of 60 months. Instead, the scheme will be phased out. From 2024 on, a percentage of 30 will apply during the first 20 months, followed by a percentage of 20 during the next 20 months, and finally, the tax-free percentage is 10% during the final 20 months. Additionally, the partial foreign tax payer status was abolished, meaning that users of the 30% ruling will have to pay taxes on all their box 3 assets starting in 2025.

The Senate was unhappy with these changes, which were implemented without prior research into their effects but are likely to deteriorate the Dutch business climate. The Senate requested the State Secretary for Finance to come up with new plans that are less harmful to the economy. They also asked to consider whether the requirement of specific expertise, currently fulfilled with a salary norm, should be tightened. Consequently, the State Secretary expedited the planned evaluation of the 30% ruling. The results of this evaluation were released last Friday.

Evaluation Outcomes
The key conclusions of the evaluation are:

1. There is no evidence that the additional costs expats incur decrease the longer they stay in the Netherlands.
2. Reducing the 30% ruling has a negative impact on the business climate.
3. The inflow of highly skilled migrants decreases by 10-15% due to the phased reduction of the scheme.
4. The 30% ruling generates more tax revenue than it costs.
5. Abolishing the partial foreign tax liability does not limit the inflow of highly skilled migrants. The benefit of the 30% ruling offsets the disadvantage of having to pay box 3 taxes.
6. The salary standard is an appropriate interpretation of the specific expertise requirement.

What’s Next?
The State Secretary has forwarded the evaluation to the House of Representatives and left a further substantive response to the new cabinet. If the new cabinet takes these outcomes seriously, it is almost certain that the phase-out of the scheme will be reversed. However, this does not apply to the abolition of the partial foreign tax liability, which seems to have been definitively scrapped following this evaluation.

Of course, we will keep you informed of further developments. If you have any questions about your specific situation, please do not hesitate to contact us.