For international hires, the first contract can decide more than the first month’s wage.
A founder hiring from abroad often hears the same question before the candidate has booked a flight: what will the Dutch salary feel like after tax? That is where the 30% ruling enters the conversation. It can make an offer workable. It can also make the first contract more important than the first payslip.
The signal has to become readable
A practical question sits behind that. What if an international specialist starts on a lower training wage, while the original contract already fixes a higher follow-up salary? The legal anchor for employers is the Hoge Raad judgment of 19 June 2015, ECLI:NL:HR:2015:1670.
That judgment places the test at the moment the employment contract is formed. The practical reading is plain: the 30% ruling starts with the salary promise, not with payroll processing.
The first contract is payroll evidence
The Belastingdienst calls the 30% ruling the expatregeling. The employee still needs the wider conditions, including employment with an employer, recruitment from outside the Netherlands, and the residence-distance rule. For most incoming employees, one hard condition is the annual wage level used to show specific expertise.
For 2026, taxable annual wage after applying the expatregeling must generally be more than €48,013. Employees under 30 with a qualifying academic master degree have a lower threshold: more than €36,497. Scientific researchers at designated institutions and physicians in specialist training sit in a different category, without that salary threshold.
Those figures make the first contract a serious document. If a specialist starts on a lower training wage, the employer needs to know what was actually agreed. A fixed later salary step in the original agreement is different from a hopeful conversation, a later repair, or a payroll note added after the problem appears.
What the signal changes
Think of a small aviation, engineering, or technical company. The candidate is recruited from abroad for a specialist role, but the first months include type training, certification, or structured onboarding. A lower starting wage may fit that path. It may also weaken the tax position if the higher wage was never fixed clearly.
Scarcity does not replace the wage test
The labour market still pushes small employers toward international hiring. UWV reported that the labour market cooled further in the first quarter of 2026, but remained tight. In 87 of 93 occupational groups, the market was still tight or very tight.
CBS reported on 3 June 2026 that 64 percent of businesses experienced staff shortages. Many firms cannot sit still for the perfect local candidate. Some automate. Others recruit abroad because the work still needs a person with the right licence, language, software knowledge, scientific skill, or operational experience.
That is the business reason for the hire. It does not replace the wage-tax conditions.
The Belastingdienst request form for 2026 asks for the date the employment agreement was signed or entered into. It also asks for the work start date and the employee’s arrival date in the Netherlands. Another question is whether employer and employee agreed that taxable annual wage after applying the expatregeling remains above the income standard.
That is administration asking whether the hiring story, legal contract, and payroll record tell the same story.
What the file should say
A small employer needs the file to be clean before the first working day. The employment agreement should show the real bargain. If there is a training wage and then a higher salary, the contract needs to make clear when that higher salary starts, what triggers it, and whether the training is part of the route into the specialist role.
The payroll record should reflect the agreement with the employee. The annual wage calculation should be watched, not remembered in December.
What founders should check
The Belastingdienst states that a decision can run for a maximum of five years, with possible reduction for earlier work or residence in the Netherlands. During the term, the employer must test whether the employee still meets the income standard.
If annual wage falls below the indexed norm, the expatregeling expires retroactively to 1 January of that year. Earlier payroll tax returns then need correction. That turns a recruitment promise into a bookkeeping problem, and sometimes into an awkward conversation with an employee who heard a net-pay promise rather than a conditional tax facility.
Timing matters too. To apply the expatregeling from the first working day, the request must be received by the Belastingdienst within four months after that day. If it arrives later, the employer may only reimburse actual extraterritorial costs tax-free until the effective date of the decision. Actual costs require proof.
The future value of the facility is changing as well. Rijksoverheid states that the maximum tax-free allowance remains 30 percent in 2025 and 2026. For 2026, the tax-free allowance is capped at €78,600 for full-year use, reached at a salary of €262,000 or higher. From 2027, the maximum falls to 27 percent, with a higher salary threshold.
A 2026 offer should not be sold as a frozen five-year 30 percent story. The transition rules depend on when the employee first used the expatregeling.
Return to the founder
Return to the founder at the start of this column. The candidate asks about net pay. The founder wants to move quickly because the vacancy hurts. That is exactly the moment to slow down for one hour and read the draft contract through the tax position. Not with fear. With discipline.
The 30% ruling can still help Dutch employers compete for scarce international talent. But it rewards clean timing, precise promises, and steady payroll control. The first payslip matters. The first contract matters more.
Sources
- CBS source
- Looneis 30%-regeling ziet ook op vastgelegd vervolgsalaris – Taxence
- Belastingdienst – Current salary test and basic eligibility
- Belastingdienst – Application timing, attachments, and payroll proof
- Rechtspraak – Contract-date principle for specific expertise
- Rechtspraak – Training and education periods in 30% ruling case law
- Belastingdienst – Decision validity and annual income testing
- Belastingdienst – Value, cap, and choice between forfait and actual costs
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