Transitional provisions
From 2027, the maximum tax-free allowance under the expat scheme (30% ruling) will be reduced from 30% to 27%. Transitional provisions apply to employees who were already applying the 30% ruling by the final payroll period of 2023: they will retain a maximum tax-free allowance of 30% for the full duration of their ruling. Employees who first applied the scheme in 2024 remain eligible for a maximum allowance of 30% in 2025 and 2026; from 2027, this will also be reduced to 27% for them.
In addition, the specific expertise requirement will become stricter from 2027. Employees who were already applying the 30% ruling by the final payroll period of 2024 will remain subject to the 2024 salary thresholds, adjusted annually for indexation, for the full duration of their ruling. The relevant factor is therefore not solely when the ruling was issued, but when the scheme was actually applied.
Employees who started applying the 30% ruling on or after 1 January 2025 will be subject to the new, higher salary thresholds from 2027. The amounts specified in the legislation are:
- €50,436 per year, excluding the tax-free allowance, for employees aged 30 and over;
- €38,338 per year, excluding the tax-free allowance, for employees under the age of 30 who hold a qualifying master’s degree.
These amounts are before indexation. The salary thresholds actually applicable in 2027 will therefore be higher.
For employees who first applied the 30% ruling in 2024, this means that from 2027 they will retain the transitional protection for the salary threshold (the indexed 2024 threshold), but will nevertheless be subject to the reduced maximum tax-free allowance of 27%.
Finally, the option to elect partial non-resident taxpayer status is generally abolished from the 2025 income tax return onwards. However, transitional provisions also apply here. Employees who were already applying the 30% ruling during the final payroll period of 2023 and who have continuously retained their status as incoming employees may still elect partial non-resident taxpayer status up to and including their 2026 income tax return. From the 2027 income tax return onwards, this option will no longer be available to anyone.
