Europe · Benelux

Netherlands

A high-functioning EU base, but the expat tax break is shrinking and there is a hard deadline this year. On 31 December 2026 the partial non-resident taxpayer status disappears. That pulls every remaining 30%-ruling holder's worldwide investment wealth into the Dutch Box 3 net.

Last verified July 2026189 visa-free destinations

Frequently asked

Is the Dutch 30% ruling still 30%?

For 2026, yes. It drops to 27% from 1 January 2027, but only for holders whose ruling started on or after 1 January 2024. Anyone whose ruling began before that keeps the full 30% for its five-year term. Watch out for stale advice. The stepped 30/20/10 taper announced for 2024 was scrapped before it fully took effect, and it is not the current law. The relief is worth up to about EUR 78,600 a year of tax-free reimbursement, capped by the WNT norm of EUR 262,000 for 2026. You must apply within four months of starting work to have it backdated to day one.

Why does the end of partial non-resident status in December 2026 matter?

Because for asset-rich families it was the real prize, and it disappears this year. Partial non-resident taxpayer status let 30%-ruling holders be treated as non-resident for Box 2 and Box 3, keeping worldwide investment wealth outside the Dutch net. It was abolished from 2025, with transitional relief only for those using the ruling in the final pay period of 2023. That transition expires on 31 December 2026. From 1 January 2027, every ruling holder becomes fully taxable as a Dutch resident on worldwide Box 1, 2 and 3 income. For a family with a nine-figure portfolio, that dwarfs the three-point cut in the headline rate.

Does the Netherlands tax wealth or capital gains?

There is no general capital gains tax on portfolio assets, but Box 3 is a wealth tax in all but name: it taxes a statutorily deemed return on net assets at 36% for 2026, above a personal exemption of EUR 59,357, payable whether or not the assets produced any income. This is the most punitive feature of the Dutch system for asset-rich families, since a portfolio that lost money still generates a tax charge, and the deemed-return basis has been the subject of years of Supreme Court litigation. Substantial shareholdings of 5% or more sit in Box 2, taxed on actual income and gains at 24.5% up to about EUR 67,804 and 31% above.

What's the cheapest EU residence permit for a US citizen?

The Dutch-American Friendship Treaty (DAFT) permit wins by an order of magnitude. You need EUR 4,500 of your own business capital, against, say, EUR 500,000 for a Portuguese fund subscription. It is a genuine self-sponsored residence permit for US citizens running a business, an eenmanszaak or BV, and it is typically decided in one to two months. Its treaty basis makes it robust rather than a discretionary programme a government can close by press release. The EUR 4,500 must stay in the business account throughout. Dipping below it is the most common way holders lose the permit. It is available only to US nationals, though a Japanese equivalent exists on similar treaty grounds.

Does DAFT come with the 30% ruling or any tax break?

No. DAFT is an immigration route, not a tax regime. A DAFT entrepreneur is a full Dutch resident taxpayer, Box 3 included. US citizens also remain taxable by the US on worldwide income no matter where they live. Box 3's deemed-return tax has no US equivalent, and that creates mismatches with the foreign tax credit. Model both systems together before you move. The permit gives you the right to live and work in the Netherlands, plus a five-year path to permanent residence. It does not shelter your income. The expedited no-documents IND procedure that ran between 2024 and 2026 is a processing convenience. It is not a relaxation of the underlying rules.

Can I keep my current citizenship if I naturalise in the Netherlands?

Generally, no. The Netherlands does not usually allow dual citizenship for adults who naturalise, so getting a Dutch passport typically means renouncing your existing nationality. That is a serious constraint. For most people, it makes Dutch residence a strategy on its own, and Dutch citizenship a separate, harder question. Naturalisation follows five years of continuous legal residence and requires passing the A2 Dutch civic-integration exam. For a US citizen on DAFT, this generally makes it a residence strategy rather than a passport strategy.

Do I actually have to have lived far from the Netherlands to get the 30% ruling?

Yes, the 150km rule is a real gate. To qualify, you must have lived more than 150km from the Dutch border for at least 16 of the 24 months before your first working day. That excludes many people who were already in Belgium, north-western Germany or northern France. You must also be recruited from abroad by a Dutch withholding agent and meet the salary norm, EUR 46,660 of taxable salary in 2026, or EUR 35,468 for under-30s with a qualifying master's. The maximum duration is five years, reduced by any prior Dutch stays in the preceding 25 years.

How long does it take to get Dutch permanent residency, and does the Netherlands have an exit tax?

Permanent residence comes after five years of continuous legal residence. The Netherlands does operate an exit tax. Inheritance tax runs at 10-20% for spouses and children, and 30-40% for others, on the worldwide estate of Dutch residents, with a 10-year tail that follows departing Dutch nationals. Top income tax in Box 1 reaches 49.5%. The passport itself is strong, consistently ranked in the top five with visa-free access to around 189 destinations as of 2026. But the dual-citizenship restriction is the sting in any plan to acquire it.

Tax position

Income tax (top)
49.5% top rate in Box 1 (employment and business income)
Capital gains
There is no general capital gains tax on portfolio assets. Instead, Box 3 taxes a deemed return on net assets at 36% (2026), above a personal exemption of EUR 59,357. Box 2, which covers substantial shareholdings of 5%+, is taxed on actual income and gains at 24.5% up to about EUR 67,804 and 31% above that.
Wealth tax
Box 3 is a wealth tax in all but name. It charges 36% of a statutorily deemed return on net worth, payable whether or not the assets actually produced any income.
Inheritance tax
10–20% for spouses and children, 30–40% for others, with substantial exemptions for spouses. This applies to the worldwide estates of Dutch residents, and a 10-year tail applies to Dutch nationals who leave the country.
Special regime
30% ruling, falling to 27% for most holders from 1 January 2027, for a maximum of 5 years
Territorial
No, worldwide income taxed
CFC rules
Yes
Exit tax
Yes, leaving has a cost
CRS
Participating

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