From 30% ruling to Expat Scheme in 2027: impact and actions for HR

For decades, the Dutch 30% ruling has been one of the country’s strongest tools to attract international talent. It offered a clear and compelling advantage: a significant portion of an expat’s salary could be paid tax-free, increasing net income while keeping employer costs competitive. But that landscape is about to shift, the 30% ruling changes in the Netherlands per 2027. From 30% ruling to Expat Scheme in 2027; what does this mean for your company and international employees?

When will the 30% ruling change to Expat Scheme?

The change in law is expected to enter into effect on 1 January 2027 (date might change).

The effective date of this measure is not yet final. Entry into force is subject to its passing through the Lower and Upper Houses (Tweede en Eerste Kamer) of the Dutch Parliament. Only after publication in the Staatsblad or Staatscourant (Government Gazette, in Dutch) the law can take effect.

While the mechanism of the current ruling remains in place in the new Implementation Decree under the Dutch Wages and Salaries Tax Act, the financial benefit will be reduced and the entry conditions tightened. For HR managers, this is more than a tax update; it is a change that will ripple through recruitment strategies, compensation models and workforce planning.

A subtle change with real impact

At first glance, the headline change seems modest: the tax-free allowance decreases from 30% to 27%. [business.gov.nl]

Yet the impact is anything but marginal. For an employee earning € 100.000, the tax-free portion drops from € 30.000 to € 27.000. That € 3.000 difference translates directly into a lower net salary.

At the same time, the bar for accessing the scheme is being raised. The minimum salary threshold will increase to approximately € 50,436, up from just over € 46,000 today. For younger employees under 30 with a master’s degree, the threshold will also rise to around €38,388. [business.gov.nl]

In practical terms, this means fewer employees will qualify. The scheme becomes more selective by design.

Moreover, there are transitional rules that complicate the application of the 30% ruling/Expat Scheme.

A more fragmented reality for HR teams

Transitional protection (grandfathering)

One of the more complex consequences of the 2027 change is that it won’t affect all employees in the same way.

Employees who already benefited from the ruling before before 1 January 2024 are generally allowed to continue applying the full 30% tax-free allowance for the remainder of their 5-year period.

This means:

• Their financial position remains unchanged until their ruling expires (max 5 years)
• They are not immediately affected by the 27% reduction in 2027

For employees whose ruling started in 2024, 2025 or 2026, the situation is different.

They can still benefit from 30% up to and including 2026, but from 1 January 2027 onwards:

• Their salary will have to meet the higher requirement for the Expat Scheme
• Their benefit will automatically drop to 27% [business.gov.nl]
• The stricter conditions (such as higher salary thresholds) start to apply

In practice, this group experiences a mid-term change during their ruling period, rather than at the start.

Meanwhile, newer hires will fall under the 27% regime. [Vergoeding 30%-regeling expats wordt 27% | Ondernemersplein]

The result? A single organisation may soon be managing multiple versions of the same scheme simultaneously.

For HR and global mobility teams, this introduces a new layer of complexity. Compensation packages will differ not just by role or seniority, but by start date. Internal fairness questions may arise. And explaining these differences to employees will require clarity and care. Payroll becomes less standardised, unless your company decides to compensate.

Whatever you decide, it’s very important to be consistent, transparent and intentional in your communication to your international workforce.

Looking ahead

The move from the 30% ruling to the revised expat scheme in 2027 reflects a broader trend: governments are reassessing how to balance international competitiveness with fiscal responsibility.

For HR leaders, this means operating in a more dynamic and complex environment.

Those who take the time now to understand, plan and adapt will be best positioned to continue attracting and retaining international talent in the years ahead.