Dutch 30% Ruling for Americans: 2026 Rules & 2027 27% Change

The 30% ruling is usually the first Dutch tax concept an incoming American learns, and the first one they learn wrong - because the rules in force depend on when the ruling was first applied, and three different cohorts now live under three different published timetables.

This article is aimed at American professionals working in the Netherlands under the 30% ruling, at those weighing an offer that mentions it, and at the professionals who prepare their returns. It describes the facility as the Belastingdienst and the statute books publish it - conditions, figures, dates and transitions - and then turns to the part that matters most for a US person: what the end of partial foreign tax liability does to a worldwide portfolio, and what the United States taxes throughout.

This article describes how United States federal tax law and the U.S. - Netherlands income tax treaty apply to US persons. It summarises Dutch rules only as published by the Belastingdienst and in the Staatsblad, for context, and is not Dutch tax, legal or succession advice - those questions belong with a Dutch-qualified professional.

What the 30% ruling is, as the Belastingdienst publishes it

The 30% ruling is a payroll facility under Dutch wage tax law (artikel 31a of the Wet op de loonbelasting 1964): an employer may pay an employee recruited from abroad up to 30% of salary as a tax-free allowance for extraterritorial costs, without itemising those costs,for a maximum of five years. For 2026 the untaxed allowance is capped at€78,600 - 30% of the €262,000 remuneration norm of the Wet normeringtopinkomens (WNT).

The published conditions are specific. The employee must be in paid employment and recruited from abroad; must satisfy the expertise test, which is a salary norm - taxable salary above €48,013 for 2026(€46,660 for 2025), or €36,497 for 2026 for employees under 30 with a qualifying master's degree, with no norm for qualifying scientific researchers and medical specialists in training; and must have lived more than 150kilometres from the Dutch border, as the crow flies, for more than 16 of the 24months before the first working day - a rule that excludes Belgium, Luxembourg and specified border regions but rarely troubles arrivals from the United States.

Two limits frame the benefit's size and length. The allowance is capped: since 2024 the facility is limited by the WNT remuneration norm, which for 2026 puts the maximum salary taken into account at€262,000 and the maximum untaxed allowance at €78,600 - figures the Belastingdienst republishes each year, so any planning conversation should quote the year's own numbers. And the clock is hard: five years is the maximum term of the facility as published - a ceiling, not an entitlement, and one reason every figure in this article carries its year.

Procedurally, the application is a joint one - "complete the application form together with your employer" - with a Belastingdienst decision within eight weeks, and on a change of employer outside a connected group a new application must be submitted within four months of starting the new job. Those are the published mechanics; whether and how to apply on particular facts is employer-and-adviser territory, not this article's.

The percentage trajectory, law by law

Three statute years tell the story. The Belastingplan 2024 (the law of 20 December 2023) cut the facility into steps - at most 30% for twenty months, then 20%, then 10%. The Belastingplan 2025reversed that before it ever ran its course: in the Belastingdienst's words,"Deze wijziging wordt per 2025 teruggedraaid" - and lowered the maximum from 30% to 27% with effect from 2027. The 2026 position is a flat 30% for everyone still inside their five years.

From 1 January 2027 the salary norms also rise: from €46,107 to €50,436,and from €35,048 to €38,338 for the under-30 master's category - both stated in2024 amounts, to be indexed. Who feels which change depends entirely on when the ruling was first applied, and the Belastingdienst publishes the transition as a three-cohort table.

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A sourcing note this series applies deliberately: the 27% change and the 2027 norms are stated here as the Belastingdienst and the government publish them, attributed to the Belastingplan 2025; the 30/20/10 step text and its reversal are quoted from the Staatsblad and the Belastingdienst's own payroll newsletter. When a rule has moved twice in two legislative years, the date on the page you are reading matters as much as the rule - which is why each figure above carries one.

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The American core: partial foreign tax liability ends, and Box 3 arrives

Until 2025, a 30%-ruling holder could elect partial foreign tax liability (partiële buitenlandse belastingplicht): for Box2 and Box 3 the Belastingdienst treated the elector "as a foreign taxpayer, even though you live in the Netherlands" (translation of the Belastingdienst's Dutch). In Box 3 that meant declaring only Dutch real estate and certain Dutch profit rights — everything else, a US brokerage account included, stayed outside the Dutch deemed-return computation.

That election is gone. The Belastingplan2024 struck the underlying provision (artikel 2.6 of the Wet inkomstenbelasting2001), and the Belastingdienst states the result plainly: from 1 January 2025 the election can no longer be made in the return. The transitional rule is equally precise: employees who received a 30% allowance over the last wage period of 2023 and have remained incoming employees without interruption" can continue to choose partial foreign tax liability up to and including the 2026 income tax return" (translation). As published, 2026 is the transitional regime's final year.

The consequence lands by cohort and by year. Someone who first held the ruling in 2024 or 2025 cannot use the transitional election - it is limited to employees with a 30% allowance over the last wage period of 2023 - so from 2025 their worldwide savings and investments sit in Box 3 under the ordinary rules, at 2026's published figures - a 6.00% deemed return on investments, 36% rate, €59,357 allowance. A pre-2024holder can still elect for the 2025 and 2026 returns; from tax year 2027 their non-Dutch investment assets enter the same computation. Which year that transition bites on your facts, and what the Box 3 base then looks like, is exactly the conversation to have with a belastingadviseur and your US professional together - the companion Box 3 article maps the regime itself.

Does the treaty change any of this? Not on anything located. Box 3 is Dutch domestic law; no treaty text retrieved for this series addresses its deemed-return computation on investment assets, and the Convention's relief articles could not be retrieved in full from the official sources online - so the end-to-end, two-return outcome on investment income is presented throughout this series as the professionals' computation. What the 2004 Protocol does address, in terms, is pension trusts: income earned inside a qualifying "exempt pension trust" - a category a published competent-authority agreement maps to 401(k) plans, IRAs and Roth IRAs among others - may be taxed "only when" paid out. A brokerage account is not a pension trust; the distinction is one more reason the account-by-account map belongs in front of both advisers at once.

The US side: nothing about the ruling changes the 1040

Through every Dutch date above, the United States taxes as it always did: a citizen or green-card holder files Form 1040on worldwide income, wherever earned and however the Netherlands labels it. No IRS guidance located for this series names the Dutch 30% ruling or its allowance - so how the allowance is treated on the US return is a question your US tax professional answers from the Code's general rules, not from a published ruling.

The working machinery is familiar. The foreign earned income exclusion is $132,900 for 2026 (Form 2555), with a housing exclusion whose 2026 ceiling is location-specific - $52,900 for Amsterdam and Schiphol, $58,400 for The Hague, $39,870 for Dutch locations not listed in Notice 2026-25. The alternative is the foreign tax credit on Form1116, basket by basket, with its carryback and ten-year carryforward. Which route - or which combination - fits a 30%-ruling salary is a modelling exercise across both returns, and the answer can change when the Dutch percentage or your cohort's rules change.

And the ruling never touched the investment side of the US return at all. Dividends, interest and gains in a US or Dutch account remain US-taxable under the ordinary rules; the net investment income tax's 3.8% applies above its unindexed thresholds, and the IRS position is that foreign tax credits "may not be used to reduce your NIIT liability. "FinCEN Form 114 (FBAR) filing is triggered once foreign accounts exceed $10,000in aggregate at any point in the year, and Form 8938's abroad thresholds - $200,000/$300,000 single, $400,000/$600,000 joint - sit alongside it. A Dutch payroll facility changes none of that arithmetic.