Stock Options and RSUs Under the Dutch 30% Ruling

How RSUs and options are taxed in the Netherlands

Before you can plan around the 30% ruling, you need to know exactly when your equity hits Dutch payroll as taxable income. RSUs and stock options follow different timing rules.

RSUs (Restricted Stock Units)

Restricted Stock Units are taxed as wage at the moment they vest. The taxable amount is the fair market value of the underlying shares on the vesting date. Whether you hold the shares or sell them immediately makes no difference to the wage tax. The vest event triggers the bill.

If 400 shares vest on 15 March at a share price of €120, you have €48,000 of wage income for that month. Your employer withholds wage tax through payroll, often by selling a portion of the shares ("sell-to-cover") on the same day.

Stock options after the 2023 reform

For stock options the timing rules changed on 1 January 2023. Under the Wet aanpassing fiscale regeling aandelenoptierechten, the default taxable moment shifted from exercise to the moment the underlying shares first become tradable. For listed-company options that is usually the moment you can exercise into freely tradable shares. For private-company options, it is typically a liquidity event such as an IPO or trade sale.

You can elect to be taxed at exercise instead, by filing a written notice with your employer before exercise (article 10a Wet LB). Most startup employees stick with the default, because it pushes the tax bill to the point where there is actually cash to pay it.

The amount taxed is the spread between the share value at the taxable moment and the exercise price you paid.

Does equity count toward the €48,013 threshold?

This is the question that catches the most people off guard. Tech offers routinely add €30,000 to €80,000 of expected annual RSU value on top of base salary. On paper your total comp comfortably exceeds six figures. The 30% ruling threshold test does not see it that way.

The threshold under article 10eb of the Uitvoeringsbesluit Loonbelasting 1965 looks at your structural employment income on an annual basis ("loon op jaarbasis"). The Belastingdienst's consistent reading: incidental wage components are out of scope. RSU vests, option gains, sign-on bonuses and discretionary bonuses generally do not count toward the test.

What does count is your base salary. To clear the standard 2026 threshold of €48,013 of taxable wage after the 30% deduction, your gross base alone needs to be around €68,590. For the under-30 Master's pathway, the equivalent gross base is around €52,139.

There is one workaround for borderline base salaries: applying for a reduced exemption percentage instead of the full 30%, so your taxable wage still clears the minimum. We covered the full math in the salary threshold edge cases post. If your base salary is genuinely too low, the only options are to renegotiate the offer or qualify under the under-30 Master's pathway.

The 30% deduction does apply to your equity income

This is the bit that works in your favour. Once the ruling is granted, the 30% exemption applies to all qualifying wage income, including equity components, subject to the Balkenende cap.

Concretely: if €40,000 of RSU value vests in March, 30% of that (€12,000) is treated as tax-free reimbursement of extraterritorial costs. Only €28,000 hits your taxable wage that month. At a 49.5% marginal rate that is roughly €5,940 saved on a single vest event.

The same logic applies to option gains taxed during the ruling period. The amount calculated at the first tradable moment (or at exercise, if you elected that route) is reduced by 30% before income tax.

One ceiling to watch. The Balkenende norm caps the total compensation against which the 30% can be applied. For 2026 the cap sits at €262,000. Above that level, your absolute tax-free amount stays fixed and the effective exemption percentage drops as your salary rises. For most expats this is academic. For senior tech leaders with large RSU vests on top of an already-high base, it can matter.

Equity granted before you arrived in the Netherlands

Equity often vests after you move. If the grant date sits before your Dutch employment began, only part of the vesting income is Dutch-taxable. The Netherlands uses a workday method to allocate equity income across the working period between grant and vest.

The mechanics are straightforward. Take the total number of working days between grant and vest. Count how many of those days you actually worked under your Dutch employment contract. Multiply the vest value by that ratio. The result is the Dutch-source portion.

The practical implication for the 30% ruling: in the year you arrive, your reported Dutch wage may be smaller than you expect because pre-arrival vesting is carved out. That can affect whether the threshold test is met for that calendar year, particularly if you arrive late in the year and most of your year-one income is a single sourced-out RSU vest.

Vesting during the ruling, taxed after it ends

The 30% ruling has a maximum duration of 60 months. What about equity that vests during the ruling but is taxed in the Netherlands only after the ruling has expired?

For RSUs this is rarely an issue because vesting and taxation happen on the same day. If the vest sits inside the ruling window, the 30% applies. If it sits outside, it does not.

For stock options it gets more interesting. Suppose your options become tradable in 2032, but your ruling expires in 2030. Under the 2023 default, the tax event is 2032. By then the ruling is gone, and the 30% does not apply to the gain, even though all of the underlying vesting happened during the ruling years.

The planning move is to look at the timing of the taxable moment, not the grant or vesting date. If you hold options approaching their tradable moment while your ruling is about to expire, look at the article 10a exercise election before the ruling ends. Triggering the taxable moment inside the ruling window can preserve the 30% benefit on a significant chunk of income.

Worked scenario: Sara at €48,000 base + €60,000 RSU

Five mistakes that cost people the benefit

1. Assuming total comp clears the threshold

The threshold test looks at structural base salary, not equity, sign-on, or annual bonus. A €60,000 base with €60,000 RSU does not pass at 30%. A €70,000 base with no equity does. Always run the math on base alone before assuming you qualify.

2. Forgetting that pre-arrival vesting is sourced out

If you arrive partway through a long vesting period, only the working days under your Dutch contract are Dutch-taxable. Year-one Dutch wage may be much lower than your annual run rate, which can also affect threshold testing for that year.

3. Exercising options the day after the ruling expires

The tax event for options is the tradable moment (or exercise, if elected). If your ruling ends on 30 June and your options become tradable on 1 July, the 30% does not apply. Time the taxable moment around the ruling expiry, not the grant date.

4. Underestimating the wage-tax spike in a vest month

Even with the 30% softening it, a €40,000 vest puts roughly €13,860 of wage tax on payroll for that single month. Sell-to-cover usually handles it, but be ready for a thin net payslip and a pile of shares in your brokerage account.

5. Treating a sign-on bonus as a salary threshold rescue

A one-off bonus does not turn into structural salary just because it is large. The Belastingdienst's reading focuses on what you earn every year of the ruling, not what landed in year one. A €30,000 sign-on bonus paid in year one will not pull a borderline base over the threshold.