Report: Evaluation of the 30% Ruling

| LIMES international

On the 14th of June, the State Secretary of Finance presented the independent evaluation report “Skills, Costs and Choices” (Kunde, Kosten en Keuzes) to the House of Representatives. The report evaluated the 30% ruling, the partial non-resident taxpayer status, and the extraterritorial costs ruling (ETK). 

Due to the 2024 changes in legislation regarding the 30% ruling and the abolition of the partial non-resident taxpayer status in 2025, the evaluation was brought forward.

In the 156-page report, the most important conclusions are as follows:

  • In practice, the extraterritorial costs remain at a constant level during the 30% ruling duration. 
  • Of the employees surveyed, 91% indicated that the extraterritorial costs are less than 30% of the gross wage.
  • A switch to the ETK scheme is to be expected when the flat rate is phased out, especially when moving from 20% to 10%. This will increase the administrative burden for employees, employers, and the tax authorities. 
  • The changes to the 30% ruling have a negative impact on the Dutch business climate. The attraction of knowledge migrants will decrease. The abolition of the partial non-resident appears not to influence the attraction of knowledge migrants. 
  • The 30% ruling generates more tax revenue than it costs.

Based on the evaluation, the new cabinet will be able to make a deliberate choice on Budget Day on the 17th of September, when the Tax Plan of 2025 is presented. It will then be decided if the recent legislative changes are kept in place or whether they will be (partially) revised, possibly retroactively.