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23-09-2024 | Legislation

From 30% ruling to (20)27% ruling

Recently, we published a post on LinkedIn about the changes regarding the 30% ruling that were expected to be announced on Prinsjesdag (Budget Day). Our expectations, which you can read about in part 1, were confirmed. However, that doesn’t mean that a new law came into existence, that still requires extensive voting. We do expect these changes to the 30% ruling to make it through the voting and be implemented in the next few years, possibly with some minor adjustments here and there.

What do we know now?

As mentioned earlier, the 30% ruling will eventually change to a 27% ruling. This will not happen in 2025 but as of January 1st, 2027. This means there will be a transitional arrangement in several areas, which we will explain in detail shortly. The salary threshold will also be significantly increased, so that incoming employees—the so-called expats—will be less likely to qualify for the brand new 27% ruling.

Enough talk. How will the next few years look like?

There will be transitional arrangements in several areas. We have summarized them for you, including changes that are already relevant as of this year (2024)!

2024:

Employees who are eligible to apply for the 30% ruling in 2024 or earlier will retain the 30% rate for the entire duration of the 30% ruling (usually 5 years or 60 months). The start date of the ruling is decisive and must include a start date in 2024 or earlier, even if the ruling is issued retroactively in 2025.

For example, an employee who receives a 30% ruling that starts on December 1st, 2024, will retain the 30% tax benefit until November 30th, 2029. The increased salary threshold will not apply to this group and will remain based on the current indexed salary threshold. This also applies to incoming employees under the age of 30 and in possession of a recognized master’s degree.

The previously announced reduction measures (from last year) are therefore completely off the table.

2025 and 2026:

Employees who receive their 30% ruling in 2025 or 2026 will already be part of the new regime, but will still enjoy the 30% benefit in both 2025 and 2026.

These employees will have a separate transitional arrangement, as they will receive a reduced benefit of 27% instead of 30% starting in 2027 but will not have to meet the increased salary criterion by 2027.

2027:

Everyone who becomes eligible for the 30% ruling after 2027 will receive only a 27% benefit and must meet a higher salary threshold, which will be indexed in the intervening years. Currently, the higher threshold is set at €50,436 (in 2024, it is €46,107), and the under30 version is set at €38,338 (in 2024, it is €35,048). It doesn’t make much sense to put too much stock in these figures as of yet, since they will be indexed in the coming years, the legislation won’t take effect for another two years, both chambers (2e kamer en 1e kamer) still need to approve it, and historically we’ve seen that until the law is written it is bound to be (slightly) altered.

In short, we now know that earlier measures will be reversed and that for the next two years not much will practically change. In 2027, if everything takes shape as is projected in this article, payroll administrators will face a greater challenge to keep track of which employees are still entitled to the 30% ruling and who has to settle for the 27% ruling if they make the salary threshold. Fortunately, you know where to find us by now, right?

 

 

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