27% Ruling: The Dutch 30% Ruling Drops to 27% in 2027

What is the 27% ruling?

The "27% ruling" is not a new scheme. It is the same 30% ruling (Expat Scheme) at a lower exemption rate: from 1 January 2027, up to 27% of gross salary can be paid tax-free instead of 30%, for rulings that start from 2027 or that are still running after their 2024-2026 transitional period ends. Eligibility rules and the 60-month maximum term stay the same. The salary norms also rise from 2027, but not for everyone: the higher norm applies to rulings first applied in payroll from 1 January 2025 onward, so to 2025 and 2026 starters as well as to new 2027 rulings, while rulings first applied in 2024 or earlier keep the old norm, indexed. The final 2027 amounts are not yet published; see the note under the phase-down table below. See also the 2026 and 2027 threshold comparison.

What Is Changing in 2027?

The Dutch government passed legislation to gradually reduce the 30% ruling (now officially called the "Expat Scheme" since 2025). The key change: from 1 January 2027 the tax-free allowance is 27% for every ruling except the pre-2024 transitional group, whether the ruling is brand new or already running.

This is part of a broader set of reforms that began in 2024. The government's stated goal is to make the ruling more sustainable while maintaining the Netherlands' competitiveness for international talent. In practice, it means new arrivals from 2027 onward will pay more in tax than employees covered by the pre-2024 transitional rules.

But the reduction to 27% isn't the only change. The abolition of partial non-resident taxpayer status (partiële buitenlandse belastingplicht) from 2025, with a transition through 2026 for the oldest rulings, has reduced the ruling's value for expats with foreign investment income. Together, these changes are the largest set of changes to the expat tax regime since the ruling was last restructured.

The Phase-Down Timeline: 30% to 27%

From 1 January 2027, every ruling drops to 27% except the pre-2024 transitional group, regardless of whether it started in 2024, 2025, 2026 or 2027 itself. The timeline:

Source: Handboek Loonheffingen 2026, section 19.4.3 and the table on p. 309; art. XXXVIIA Belastingplan 2024. The 2027 salary norms are not final yet. The Handboek Loonheffingen 2026 (p. 303) gives €51,899 and €39,450, to be indexed again; the draft Fiscaal verzamelbesluit 2026 gives €52,521 and €39,923 before the final 2027 indexation. Final figures are expected in December 2026.

The critical point: the rate you receive depends on when the ruling takes effect, which is tied to your employment start date and application filing. If you start working in 2026 and file within the 4-month deadline, the ruling should take effect from your 2026 start date, even if the Dutch Tax Authority issues the approval letter in 2027. Starting in 2027, or filing so late that the ruling only takes effect in 2027, means the 27% rate applies instead.

Who Is Affected, and Who Isn't

Everyone whose ruling was first applied in payroll before 1 January 2024 keeps 30% for the full term; everyone else moves to 27% from 1 January 2027, whether their ruling is brand new or already running.

Not Affected (You Keep 30%)

• Pre-2024 ruling holders: If your employer already applied the ruling in your payroll over the last pay period of 2023 and you have not since become a new incoming employee after a gap of more than 3 months, transitional law applies: you keep the full 30% for your entire remaining term. The phase-down does not reach this group.
• Employer changes within a transitional ruling: if you change employers and the new employment contract is concluded within 3 months after the old employment ended, you and the new employer can jointly request continuation of the ruling for its remaining term (art. 10ed UB LB 1965); the new employer must again show you meet the conditions, and the transitional 30% travels with you. The request follows the normal timing rule: received within 4 months of your first working day at the new employer for it to apply from that day.

Affected (You'll Get 27%)

• Everyone who first used the ruling in 2024, 2025 or 2026: You receive 30% through 31 December 2026. From 1 January 2027 your rate becomes 27% for the remaining months of your ruling. The change happens automatically; no new application is needed.
• New arrivals from 2027: Anyone who starts working in the Netherlands from January 1, 2027 and applies for the ruling will receive the 27% rate for the full term.
• Late 2026 starters who file late: if you start in late 2026 and the Tax Authority receives your request more than 4 months after your first working day, the ruling starts on the first day of the month after receipt and the months before are taken off your term. You keep the ruling, but you lose the retroactive 2026 months and the 30% rate for them.
• Anyone who starts employment from January 1, 2027: Regardless of when you signed the contract or received the offer, the ruling takes effect from your first working day. A 2027 start date means the 27% rate.

Who Keeps 30%: the Transitional Rules

The only group that keeps the full 30% for its entire term is the group that already applied the ruling in a payroll over the last pay period of 2023, without a later gap of more than 3 months before re-qualifying as an incoming employee. That transitional window is closed: it is no longer possible to join it. For everyone else, the calendar decides the rate, not the approval date:

• First used the ruling before 1 January 2024: 30% for the full term, under transitional law.
• First used the ruling in 2024, 2025 or 2026: 30% through 31 December 2026, then 27% from 1 January 2027 for the remaining months.
• Ruling starting from 1 January 2027: 27% for the full term.
• What still matters in 2026: starting and filing promptly gets you the 30% rate for the rest of 2026. A request received within 4 months of your first working day applies from that day; a later request starts the ruling from the month after receipt and shortens the term. Use our calculator to verify you meet the salary threshold: taxable wages above €48,013 (above €36,497 if you are under 30 with a qualifying master's degree).

Partial Non-Resident Taxpayer Status: Abolished, with a Transition Through 2026

The phase-down from 30% to 27% gets most of the headlines, but for many expats, the abolition of partial non-resident taxpayer status (partiële buitenlandse belastingplicht) is the bigger financial blow, and it is already in effect.

Through the 2024 tax year, 30% ruling holders could elect to be treated as partial non-resident taxpayers. This meant that income from foreign assets in Box 2 (substantial shareholdings) and Box 3 (savings and investments) was exempt from Dutch tax. For expats with significant investment portfolios, foreign property, or shares in foreign companies, this was enormously valuable.

From the 2025 tax return onward this election is no longer available for most ruling holders. Foreign savings, investments, rental income and dividends then fall under Dutch Box 2 and Box 3 taxation like for any other resident.

There is a transitional rule (art. XIIA Belastingplan 2024). If your employer applied the 30% ruling in your payroll over the last pay period of 2023, and you have not since become a new incoming employee after a gap of more than 3 months, you can still elect partial non-resident status in your 2025 and 2026 tax returns, for as long as your ruling runs in those years. From the 2027 tax return onward the election is gone for everyone. Sources: Handboek Loonheffingen 2026, section 19.4.7 (p. 313), and the Belastingdienst page on partiële buitenlandse belastingplicht.

The Financial Impact: How Much More Will You Pay?

In numbers: the difference between a 30% and 27% exemption.

Use our interactive calculator to see the exact impact for your salary level.

Estimates from the same model as our calculator: 2026 Box 1 brackets (35.75% to €38,883, 37.56% to €78,426, 49.50% above), no tax credits or social-security nuances, salary below the 2027 WNT cap of €273,000. The 2027 brackets are still a bill (Belastingplan 2027) and are not applied here. For lower salaries the 27% figure depends on which salary norm applies to your cohort, and the 2027 norm is not final, so they are not shown; use the calculator and read its norm note.

What You Should Do Now

If You're Already in the Netherlands with a 30% Ruling

Check which group you are in. Did your employer already apply the ruling in your payroll over the last pay period of 2023? Then transitional law keeps you at 30% and the phase-down passes you by. Did you start in 2024 or later? Then budget for the automatic step to 27% on 1 January 2027: at a €100,000 gross salary that is roughly €1,100 per year in extra tax (2026 brackets, before tax credits). In both cases, review your Box 2 and Box 3 position: the partial non-resident election is gone from the 2025 return for most holders and ends with the 2026 return for the transitional group. If your ruling is also approaching its end date around the same time, see our guide on what changes when your 30% ruling ends.

If You're Planning to Move to the Netherlands in 2026

A 2026 start still pays: you get the 30% rate for the months of 2026, and every month of delay pushes more of your ruling into the 27% era. The 4-month window decides whether the ruling reaches back to your first working day; it does not decide whether you get the ruling. Here's your action plan:

• Negotiate your start date: If you're in negotiations with a Dutch employer, push for the earliest possible start date in 2026.
• Prepare documents in advance: Have your diplomas, CV, proof of residence history, and contract ready before day one. Don't wait until after you start to begin gathering paperwork.
• File within the first month: the Tax Authority must receive the request within 4 months of your first working day for the ruling to apply from that day. Filing early means the ruling, and the 30% rate for the rest of 2026, lands in your payroll sooner.
• Verify your salary qualifies: check that your taxable wage after the allowance stays above the 2026 norm, and note that if your ruling is first applied in 2025 or 2026, the higher 2027 norm applies to you from 1 January 2027. See the 2026 threshold requirements.
• If you start in 2025 or 2026: check the 2027 norm against your taxable wage once the final figure is published.

If You're Planning to Move in 2027 or Later

The 27% ruling is still a significant tax benefit. It is less generous than the 30% rate, but a substantial portion of income remains tax-free under it.

Common Questions About the 2027 Changes

Is the 27% ruling a new scheme?

No. It is the existing 30% ruling (Expat Scheme) with the tax-free percentage reduced to 27% for rulings that run from 2027 onward, or that reach 2027 outside the pre-2024 transitional group. The application process and the 60-month maximum term are unchanged, but the salary norms also rise from 2027 for rulings first applied from 1 January 2025 onward (final 2027 amounts not yet published). Only the exemption rate and those norms move.

Who keeps 30% in 2027?

Only employees whose employer already applied the ruling in payroll over the last pay period of 2023, with no later gap of more than 3 months before re-qualifying as an incoming employee. They keep the full 30% for their entire remaining term under transitional law. Everyone who started using the ruling from 2024 through 2026 gets 30% through 31 December 2026 and then 27% from 1 January 2027 for the rest of their term.

Does applying in 2026 guarantee 30% for the full term?

No. Starting and filing in 2026 secures the 30% rate only through 31 December 2026. From 1 January 2027, the rate drops to 27% for the remaining months of the ruling, the same as for anyone else who first used it in 2024, 2025 or 2026. Applying in 2026 does not secure 30% for a full 5-year term.

Will the rate drop further below 27% in future years?

There is no current legislation for further reductions beyond 27%. However, the political landscape can change. The reduction from 30% to 27% was itself the result of a political compromise: earlier proposals suggested reducing it to 20% or eliminating it entirely. 27% is the enacted rate (Stb. 2024, 434).

Can I apply in 2026 even if I started working in 2025?

Yes, you can still apply even after the 4-month window from your first working day has passed. What changes is the effective date: instead of applying retroactively to your start date, the ruling starts from the first day of the month after you file the request (art. 10ei lid 2 UB LB 1965). The months between your actual start date and that later effective date are lost from the 60-month maximum term (art. 10eg UB LB 1965), so filing late shortens the ruling rather than blocking it.

What if I start in December 2026: do I still get 30%?

Yes, for December 2026 itself: if you start employment in 2026 and file within 4 months of your first working day, the ruling applies retroactively from your 2026 start date at 30%, even if the Dutch Tax Authority only processes it in 2027. From 1 January 2027 the rate becomes 27% for the remaining months, like for everyone who started from 2024 onward.

Does the 60-month maximum duration change?

No. The maximum duration remains 60 months (5 years) regardless of whether you receive the 30% or 27% rate. Time previously spent in the Netherlands may reduce this duration; consult the FAQ for details.

I'm changing employers in 2027. Will my rate drop from 30% to 27%?

The employer change itself does not change your rate; the calendar and your start group do. If your ruling was applied in payroll over the last pay period of 2023, the transitional 30% travels with you to the new employer, provided the new contract is concluded within 3 months after the old employment ended and you file a joint request for continuation (received within 4 months of your new first working day for it to apply from that day). If your ruling was first applied from 2024 onward, you are at 27% from 1 January 2027 with any employer. Read our guide on changing employers for the full process.