Global Mobility Services

With our comprehensive Global HR services in Technology, Advisory, and Support, we provide expert guidance and support to our international clients. We offer professional advice on tax and legal matters related to cross-border employment, including payroll taxes and social security. Our solutions include advanced international HR software and data analytics. Additionally, we manage your needs through our International Payroll and HR Coordination services, ensuring seamless and efficient operations.

 

More clarity about the limitations in the 30%-ruling for expats?

Our partners from the Global Mobility Team at Crowe Foederer would like to inform you about the recently published evaluation of the (cutbacks in the) 30%-ruling that came into force per January 1, 2024. The House of Representatives requested this evaluation. The changes effective from January 1, 2024 include:

  1. Introduction of a cap for the 30% ruling.
  2. Degression percentage of the tax-free allowance on income for incoming employees:
    • 30% of taxable income for the first 20 months
    • 20% for the next 20 months; and,
    • 10% for the last 20 months.
  3. Abolition non-resident taxpayer treatment.

Upon the introduction of the aforementioned cutbacks in the 30% ruling, the Senate passed a motion on December 19, 2023, requesting that the planned evaluation of the 30% ruling would be brought forward due to concerns that the measures might have a potentially undesirable and adverse effect on the Dutch economy. This evaluation was recently conducted, and on June 14, 2024, the report was presented to the House of Representatives.

The key findings from the report are as follows:

  • The 30% ruling generates more tax revenue than it costs.
  • Frequent changes to the 30% ruling harm the business climate due to a lack of predictability and stability.
  • No evidence has been found to justify a reduction in extraterritorial costs (ETK) as the duration of stay increases.
  • The introduction of a reduction leads to increased use of the ETK scheme, making the scheme less effective and increasing administrative burdens for both taxpayers and the Tax Authorities.
  • The influx of highly skilled migrants is expected to decrease by 10-15% due to the reduction of the allowance. In case of full abolition, this influx would decrease by 40%.
  • The abolition of the non-resident taxpayer treatment has little impact on the influx of highly skilled migrants.
  • Raising the salary norm is less aligned with the labor demand of employers, especially for startups and scale-ups.

The consequences of these findings for the reduction of the 30% ruling are not yet known. The report at least provides insight into the negative effects of further reductions in the 30% ruling and may lead to a reconsideration of the reductions in the (near) future. We will keep you posted!

For further information about the 30% ruling and its possible reductions, please contact our partners at Crowe Foederer.

Contact one of our Global Mobility specialists

Roeland van Esveld
Partner Global Mobility Services +31 (0)6 13 96 89 83
Sander van de Schoot
Senior Consultant Global Mobility +31 (0)6 31 59 25 05