The Netherlands has set ambitious goals for technological innovation, the energy transition, and productivity growth leading up to 2035. These targets are only achievable if enough international technical talent is willing to move here and stay here. That makes it worth looking at every Prinsjesdag to see whether the fiscal policy supports or undermines that narrative.
On September 15, 2026, the cabinet presented the Tax Plan 2027. The core question: while we try to attract that talent, are we still paying attention to how the Netherlands positions itself? Companies that believe in what the Netherlands has to offer attract different people than companies that simply forward the tax rules. That is a consideration for both policymakers and employers.
27% in 2027
The cabinet is definitively lowering the flat-rate percentage of the expat ruling from 30% to 27% as of January 1, 2027. For new cases and expats already covered by the ruling, this means an immediate drop in net disposable income. The income threshold to qualify for the ruling will also rise. Transitional law applies to employees who already had the ruling in the final payroll period of 2023: they retain the 30% rate for the full duration of their decision. Anyone who started after January 1, 2024, will switch to the lower rate next year.
The salary standards are also increasing for 2027, but that is the standard annual indexation. Not a new measure, but a point to watch if you are filing an application in the coming months.
Partial non-resident tax liability: the end of the transition period
The option for partial non-resident tax liability, which allowed expats to be treated as non-resident taxpayers for box 2 and box 3, expires definitively on January 1, 2027. A transitional arrangement is already in place for those who used the ruling in the final payroll period of 2023, but that too will expire. After 2026, the exemption ends for everyone.
For expats with savings, investments, or a substantial interest in a foreign company, this could mean a noticeable tax increase. It is wise to discuss this with them before the end of the year.
Box 3 waits a little longer
The Actual Return Box 3 Act (Wet werkelijk rendement box 3) has been put on hold. The cabinet has not yet made a definitive choice on the direction of the new system. The intended implementation on January 1, 2028, is now uncertain; alternatives are being considered, including a capital gains tax where tax is only levied upon sale.
For expats with foreign assets, the current uncertainty therefore remains for the time being. We are tracking the parliamentary proceedings.
Staff discount now falls under the free space
A small but relevant change for HR: the separate tax exemption for staff discounts on industry-specific products disappears on January 1, 2027. Employees who currently receive a tax-free discount on their employer’s products, up to a maximum of 500 euros and a 20% discount, can still enjoy that benefit, but it will now fall under the free space (vrije ruimte) of the work-related costs scheme (werkkostenregeling). If that space has already been used, you as the employer will pay a final levy.
For higher incomes: pension cap frozen
For employees with a pensionable salary above 137,800 euros, the capping limit for tax-efficient pension accrual will not be indexed from 2027 up to and including 2032. In practice, this means an annual reduction in the fiscal space for pension accrual at the top end. If you employ people at this salary tier, factor this into your upcoming compensation talks.
Stock options for startups and scale-ups
The Tax Plan 2027 includes the Tax incentive act for start-ups and scale-ups (Wet fiscale stimulering start-ups en scale-ups).
The core is twofold. First, the moment of taxation is postponed until the employee actually sells the shares. This solves the well-known liquidity problem, where employees had to pay tax on shares they could not yet cash in. Second, only 65% of the sales benefit is counted towards taxable wages, bringing the effective tax pressure down to a level comparable with box 2.
The scheme will apply to companies with an official RVO designation as a start-up or scale-up, has a holding period of two years, and does not apply if a substantial interest already exists.
The intended effective date is January 1, 2027.
For international tech companies and scale-ups attracting talent with a mix of salary and stock options, this is a welcome development, and a new argument in the conversation about the Netherlands as a place of business.
The mixed signal
The stock option scheme for startups is a step in the right direction. But when you put the developments side by side, they do not send a clear signal: a reduction from 30% to 27%, the definitive end of the partial non-resident tax liability, and higher administrative hurdles on one side, against a new incentive scheme for scale-ups on the other. Fiscally, there are arguments for each of these choices. As a narrative for international talent, it is less coherent.
Peter Wennink (former ASML CEO) drew exactly this conclusion in his report The route to future prosperity (December 2025, commissioned by the cabinet). Without structural choices in the areas of international talent, investment, and the business climate, the Dutch earning capacity will be under pressure in the long term. He explicitly named the scaling back of the expat ruling as an example of policy that makes attracting knowledge workers harder, while the Netherlands desperately needs that talent.
Most changes take effect on January 1, 2027. That sounds far away, but it is only a quarter from now. Do you want to know the impact for your specific situation or for one of your employees?
Get in touch. We will calculate the financial and administrative consequences for you and ensure your organization is ready for the new rules.