How does relocation to the Netherlands affect your home country taxes?

Russell Advocaten · 17 okt 2026

Relocating to the Netherlands does not automatically end your tax obligations in your home country. Whether those obligations continue depends on your tax residency status, the terms of any applicable double tax treaty, and the specific rules of your home country’s tax legislation. For many expats moving to the Netherlands, a period of overlapping tax liability in two jurisdictions is common, particularly during the year of the move itself. The sections below address the most important questions that arise when international relocation intersects with home country taxes.

Does leaving your home country end your tax obligations there?

Leaving your home country does not automatically terminate your tax obligations there. Most countries continue to tax former residents on certain types of income for a period after departure, and some, notably the United States, tax their citizens on worldwide income regardless of where they live. Whether your home country tax obligations cease, reduce, or continue depends on that country’s domestic rules for determining when a person is no longer considered a tax resident.

In practice, many countries require a formal process to sever tax residency. This may involve notifying the tax authority, deregistering from the population register, demonstrating that your centre of life has genuinely moved, or satisfying a minimum number of days spent outside the country. Simply obtaining a Dutch residence permit or starting work in the Netherlands is rarely sufficient on its own to end home country tax liability.

Some home countries impose an exit tax on unrealised capital gains or on pension entitlements at the moment of departure. Others maintain a deemed residency rule for a fixed period, sometimes up to ten years, after a person leaves. The specific consequences of international relocation vary considerably by jurisdiction, and it is advisable to take professional advice in your home country before or shortly after your move.

What is tax residency and how is it determined after a move?

Tax residency is the legal status that determines which country has the primary right to tax your worldwide income. After relocating to the Netherlands, you may become a Dutch tax resident while simultaneously remaining a tax resident of your home country under that country’s domestic rules, a situation known as dual tax residency. Each country applies its own criteria to determine residency, and these criteria do not always align.

Common factors used to determine tax residency include:

The number of days spent in a country during the tax year
The location of your permanent home or habitual abode
Where your family, social, and economic ties are centred
Your intention to remain in a country for an indefinite period
Registration in a country’s official population records

In the Netherlands, tax residency is assessed on the basis of all relevant facts and circumstances, with particular weight given to where a person’s durable ties are located. Registering with your local municipality (gemeente) and entering the Personal Records Database (BRP) is an important step upon arrival, but registration alone does not determine tax residency for Dutch tax purposes: the substantive circumstances of your life are what matter.

Where both the Netherlands and your home country claim you as a tax resident simultaneously, the question of which country has the primary taxing right is resolved by reference to a double tax treaty, if one exists between the two countries.

What does a double tax treaty do for relocating expats?

A double tax treaty is a bilateral agreement between two countries that allocates taxing rights over different categories of income and prevents the same income from being taxed in full by both countries. For expats moving to the Netherlands, a double tax treaty between the Netherlands and their home country can significantly reduce or eliminate double taxation on employment income, investment returns, pensions, and other sources of income.

When both countries claim tax residency over the same individual, most double tax treaties include a tie-breaker clause. This clause applies a hierarchy of criteria, typically permanent home, centre of vital interests, habitual abode, and nationality, to determine which country is treated as the country of residence for treaty purposes. The outcome of this analysis determines which country taxes your worldwide income and which country is limited to taxing only income sourced within its borders.

Double tax treaties also typically provide mechanisms such as:

Exemption with progression: the country of residence exempts foreign-source income from tax but takes it into account when calculating the applicable tax rate on remaining income
Tax credits: the country of residence taxes worldwide income but grants a credit for taxes paid in the source country, reducing the overall tax burden
Reduced withholding rates: lower rates of tax on dividends, interest, and royalties paid across borders

The Netherlands has an extensive network of double tax treaties. However, treaty provisions vary considerably in their scope and detail, and not every type of income or every personal circumstance is covered. Where no treaty exists, domestic relief mechanisms may still apply, but the risk of genuine double taxation is higher.

Which home country taxes can still apply after relocating to the Netherlands?

Even after establishing tax residency in the Netherlands, several categories of home country tax may continue to apply. The most common are taxes on income sourced within the home country, taxes on assets located there, and, in the case of certain nationalities, taxes on worldwide income regardless of residence.

Categories of home country tax that frequently persist after relocation include:

Rental income from property: most countries retain the right to tax income derived from real estate situated within their borders, even if the owner lives abroad
Capital gains on domestic assets: gains on the sale of shares, property, or business interests located in the home country are often taxable there under both domestic law and treaty provisions
Pension income: depending on the treaty, pension payments may be taxable in the country of residence, the country of source, or both; the allocation varies significantly by treaty and by the type of pension
Citizenship-based taxation: US citizens and certain other nationals remain subject to worldwide income tax in their home country regardless of where they live, requiring annual filing obligations even after years of residence in the Netherlands
Inheritance and gift taxes: some countries impose inheritance or gift tax obligations based on the nationality or former domicile of the donor, which can affect transfers made after departure

The year of the move itself is frequently the most complex from a tax perspective, as income may be split between two tax years in different countries, and transitional rules may apply. Keeping detailed records of income, assets, and days spent in each country during the year of relocation is particularly important.

What is the 30% ruling and how does it interact with home country taxes?

The 30% ruling, formally known as the expat scheme, is a Dutch tax facility that allows qualifying employers to pay up to 30% of a foreign employee’s salary tax-free as compensation for the additional costs of working in the Netherlands. As of 2026, the maximum untaxed allowance under the scheme is €78,600 per year, applicable to employees earning €262,000 or more. For employees under 30 with a Dutch academic master’s degree or equivalent, a lower salary threshold of €36,497 applies.

To qualify, an employee must be recruited from abroad, must have lived more than 150 kilometres from the Dutch border for at least 16 of the 24 months before their first Dutch working day, and must possess specific expertise that is scarce in the Dutch labour market. The employer must apply to the Dutch Tax Administration for a formal decision (beschikking) within four months of the employee’s first working day.

Changes to the scheme from 2027

Employees who became eligible for the expat scheme after 1 January 2024 should be aware that the maximum tax-free reimbursement will reduce from 30% to 27% as of 1 January 2027. The scheme is also subject to a cap based on the maximum remuneration standard (the Balkenende norm), which is set annually. Given that further changes are planned in the coming years, it is advisable to consult a tax specialist to understand how upcoming amendments may affect an ongoing arrangement.

Loss of partial foreign tax liability since 2025

A significant change took effect on 1 January 2025: employees using the expat scheme can no longer apply for partial foreign tax liability (partiële buitenlandse belastingplicht) in their Dutch income tax return. Before 2025, scheme users were treated as foreign taxpayers for Box 2 (substantial interest) and Box 3 (savings and investments), meaning foreign capital income in those categories was not taxed in the Netherlands. Since 2025, that income must be declared in the Netherlands. This change has direct implications for expats who hold significant assets or shareholdings in their home country, as those assets may now be subject to Dutch taxation alongside any continuing home country obligations.

The interaction between the 30% ruling and home country taxes is therefore not straightforward. The scheme reduces Dutch wage tax on employment income, but it does not eliminate home country tax obligations, and the 2025 changes may increase Dutch tax exposure on assets that were previously outside the Dutch tax net.

When should a relocating expat seek cross-border tax advice?

A relocating expat should seek cross-border tax advice before the move takes place, not after. The decisions made in the months immediately before and after relocation, including the timing of asset disposals, the structure of employment arrangements, and the formal steps taken to sever home country tax residency, can have lasting consequences that are difficult or impossible to reverse once the move has occurred.

Specific situations that warrant professional advice include:

Holding property, shares, or pension entitlements in your home country at the time of the move
Being subject to citizenship-based taxation (particularly relevant for US nationals)
Receiving income from multiple countries simultaneously
Applying for or currently benefiting from the Dutch expat scheme
Planning to return to your home country within a few years
Receiving gifts or inheritances from family members in your home country after relocating
Changing employers in the Netherlands, which may affect the continuity of an existing expat scheme decision

Cross-border tax situations involve the interaction of at least two legal systems, and the outcome in any given case depends on the specific facts, the applicable treaty, and the domestic rules of both countries. General information of the kind set out in this article provides a framework for understanding the issues, but it cannot substitute for advice tailored to your individual circumstances.

How Russell Advocaten supports expats with cross-border legal questions

Russell Advocaten is an internationally oriented law firm based in Amsterdam with over 80 years of experience advising expats, foreign businesses, and international organisations on legal matters in the Netherlands. The firm’s lawyers communicate fluently in English, German, and Dutch, making them well placed to assist clients who are navigating a new legal and regulatory environment.

For expats dealing with the legal dimensions of international relocation, Russell Advocaten offers practical assistance across a range of areas:

Advising on employment contracts and the legal framework surrounding the expat scheme
Assisting with the legal aspects of setting up a business in the Netherlands as a foreigner
Advising on real estate transactions, including renting and buying property in the Netherlands
Providing guidance on immigration and residence permit requirements
Supporting clients on contract negotiations and corporate structuring
Assisting with family law matters that arise in an international context

Russell Advocaten is an official partner of IN Amsterdam, the expat centre of the City of Amsterdam, and is a member of the Primerus network of independent law firms across 40 countries, providing access to coordinated legal support for cross-border matters. The firm has been recommended by the Legal 500 for many years.

If you are planning a move to the Netherlands or are already based here and have questions about the legal aspects of your situation, contact Russell Advocaten to discuss how the firm can assist you.

This information is general in nature and does not constitute legal advice for your specific situation. Please consult a lawyer at Russell Advocaten for advice tailored to your circumstances.

Veelgestelde vragen

How do I formally sever tax residency in my home country before moving to the Netherlands?

The exact process depends on your home country’s rules, but it typically involves deregistering from the local population register, notifying your national tax authority of your departure, and in some cases filing a final resident tax return. You may also need to demonstrate that your centre of life has genuinely shifted to the Netherlands by showing evidence such as a Dutch employment contract, a Dutch rental or purchase agreement, and BRP registration with your local gemeente. Because the requirements differ significantly by jurisdiction, it is strongly advisable to consult a tax adviser in your home country before you move, rather than assuming the process is automatic.

What happens if there is no double tax treaty between the Netherlands and my home country?

If no treaty exists, both countries may tax the same income under their respective domestic rules, creating a genuine risk of double taxation. The Netherlands does offer unilateral relief through the Besluit voorkoming dubbele belasting (the Decree for the Prevention of Double Taxation), which can reduce Dutch tax on certain foreign-source income even in the absence of a treaty. However, whether your home country offers equivalent relief depends entirely on its own domestic legislation. In the absence of a treaty, careful tax planning and professional advice become even more important, as the combined tax burden can be substantially higher than in a treaty situation.

I am a US citizen moving to the Netherlands — do I still need to file US tax returns every year?

Yes. The United States applies citizenship-based taxation, meaning US citizens are required to file annual federal tax returns and report their worldwide income regardless of where they live. You will also likely have FBAR (FinCEN 114) and FATCA (Form 8938) reporting obligations if you hold financial accounts or assets in the Netherlands above certain thresholds. The US–Netherlands double tax treaty and the Foreign Tax Credit mechanism can help reduce or eliminate actual US tax liability in many cases, but the filing obligations themselves remain, and failure to comply can result in significant penalties. Working with a tax adviser experienced in US expatriate taxation is essential.

If I still own property in my home country after relocating to the Netherlands, what are my tax obligations on rental income?

Rental income from property located in your home country is almost universally taxable there, regardless of where you live — this is one of the most consistently applied principles in international tax law and is preserved in virtually all double tax treaties. In the Netherlands, that same rental income may also be reportable, but the applicable treaty will typically either exempt it from Dutch tax or allow a credit for the home country tax paid. You should also be aware that the property itself may be taken into account under the Dutch Box 3 system for savings and investments, even if the rental income is exempt, so it is worth reviewing your overall Dutch tax position with an adviser.

Can I lose my eligibility for the 30% ruling if I change jobs in the Netherlands?

Changing employers does not automatically end your entitlement to the 30% ruling, but the continuity of the scheme is not guaranteed either. When you change jobs, your new employer must submit a fresh application to the Dutch Tax Administration within four months of your first working day with them, and the new arrangement is subject to the remaining duration of your original eight-year entitlement period. If there is a gap between jobs, or if the new employer fails to apply in time, you may lose the benefit for the intervening period or entirely. It is important to plan any job change carefully and to ensure your new employer is aware of the application requirement well in advance.

How does the 2025 removal of partial foreign tax liability affect expats with investments or shareholdings abroad?

Before 2025, expats using the 30% ruling could elect for partial foreign tax liability, which meant their foreign assets in Box 2 (substantial interest, generally shareholdings of 5% or more in a company) and Box 3 (savings, investments, and other capital) were not subject to Dutch taxation. Since 1 January 2025, this election is no longer available, meaning those assets must now be declared in the Netherlands and may be taxed here alongside any continuing obligations in the home country. Expats with significant foreign investment portfolios, business shareholdings, or savings held abroad should urgently review their Dutch tax position to understand the impact and explore whether any restructuring or treaty relief is available.

What records should I keep during the year I relocate to the Netherlands to protect myself in case of a tax audit?

The year of relocation is the most complex from a tax perspective, and thorough documentation is your best protection. You should keep a detailed day-count diary recording which country you were physically present in on each day of the year, along with supporting evidence such as travel receipts, boarding passes, and hotel records. Retain all documentation relating to the timing of your move — your lease or purchase agreement in the Netherlands, your deregistration date in your home country, your BRP registration confirmation, and your employment start date. You should also document the status of any assets, pensions, or investments at the exact date of departure, as this information is often needed to calculate exit tax liabilities or to establish the base cost of assets for future capital gains purposes.

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