Partial Non-Resident Taxpayer Status
How the partial non-resident taxpayer status works with the 30% ruling, allowing you to be treated as a non-resident for Box 2 and Box 3.
Key Takeaways
- Partial non-resident taxpayer status was repealed as of January 1, 2025.
- Transitional rules apply: if you were already using the scheme before January 1, 2024, you can continue to use it through December 31, 2026.
- Under this status, you are treated as a resident for Box 1 but as a non-resident for Box 2 and Box 3.
- This means foreign savings, investments, and substantial interests are exempt from Dutch tax.
- From 2027 onward, partial non-resident status will no longer be available to anyone.
Warning
Important change: The partial non-resident taxpayer status was abolished as of January 1, 2025. If you were already using this status before 2024, transitional rules allow you to continue through 2026. All other 30% ruling holders can no longer elect this status. From 2027, no one can use it regardless of when their ruling was granted.
What Is Partial Non-Resident Status?
When you live in the Netherlands, you are normally a resident taxpayer (binnenlands belastingplichtige). This means the Netherlands taxes your worldwide income across all three boxes.
Partial non-resident status creates a split:
| Box | Treated As | What This Means |
|---|---|---|
| Box 1 (work and home) | Resident | All Box 1 income is taxed normally — salary, business profit, home ownership |
| Box 2 (substantial interest) | Non-resident | Only Dutch substantial interests are taxed. Foreign company shares (5%+) are exempt |
| Box 3 (savings and investments) | Non-resident | Only Dutch real estate is taxed. Foreign bank accounts, stocks, bonds, crypto are exempt |
Why This Matters
For expats with significant assets abroad, partial non-resident status can save thousands of euros per year. Here are the most common scenarios:
Savings in Foreign Bank Accounts
If you have €200,000 in savings at a bank in your home country, under normal resident status this would be included in your Box 3 assessment. With partial non-resident status, it is exempt.
Investment Portfolios Abroad
Foreign stock portfolios, bond holdings, mutual funds, and other investment accounts held at non-Dutch financial institutions are exempt from Box 3.
Property Abroad
Real estate in your home country (such as an apartment you still own but rent out) is exempt from Box 3 under partial non-resident status.
Shares in Foreign Companies
If you hold 5% or more of a foreign company (a substantial interest), the dividends and capital gains are exempt from Box 2 under partial non-resident status.
Good to know
The exemption applies to foreign assets only. If you open a Dutch bank account, buy shares through a Dutch broker, or purchase property in the Netherlands, those assets remain subject to Dutch tax regardless of your partial non-resident status.
How Much Can You Save?
Example 1: Moderate Savings
Situation: You have €150,000 in savings at a bank in Germany.
| Normal Resident | Partial Non-Resident | |
|---|---|---|
| Box 3 assets | €150,000 | €0 (foreign, exempt) |
| Tax-free threshold | −€59,357 | N/A |
| Taxable base | €93,000 | €0 |
| Approximate Box 3 tax | ~€550 | €0 |
| Annual saving | ~€550 |
Example 2: Substantial Foreign Portfolio
Situation: You have €500,000 in investments at a brokerage in the US and €100,000 in a UK savings account.
| Normal Resident | Partial Non-Resident | |
|---|---|---|
| Box 3 assets | €600,000 | €0 (all foreign, exempt) |
| Tax-free threshold | −€59,357 | N/A |
| Taxable base | €543,000 | €0 |
| Approximate Box 3 tax | ~€6,800 | €0 |
| Annual saving | ~€6,800 |
Example 3: Shares in a Foreign Company
Situation: You own 25% of a company in India worth €400,000.
| Normal Resident | Partial Non-Resident | |
|---|---|---|
| Box 2 applicable | Yes (substantial interest) | No (foreign, exempt) |
| If dividends paid: €40,000 | Tax: €9,800 (24.5%) | €0 |
| Annual saving | €9,800 |
Box 2 rates for 2026: 24.5% on the first €68,843, and 31% above that threshold.
Warning
These examples are simplified. The actual Box 3 calculation uses deemed returns and specific brackets. The key point is that partial non-resident status can exempt substantial foreign assets from Dutch taxation.
How to Elect Partial Non-Resident Status
Step 1: Have a Valid 30% Ruling
Partial non-resident status is only available if you have an active 30% ruling. Without the ruling, you cannot elect this status.
Step 2: Make the Election on Your Tax Return
When filing your annual tax return (aangifte inkomstenbelasting), you tick the box for "partieel buitenlands belastingplichtige" in the relevant section. This is done each year — you can choose it one year and not the next.
Step 3: Report Only Dutch Assets in Box 2 and Box 3
Once you have elected partial non-resident status, you only report:
- Box 2: Substantial interests in companies established in the Netherlands
- Box 3: Real estate located in the Netherlands
All foreign assets are omitted from your return.
Tip
You must actively make this election. It is not automatic. Many expats with the 30% ruling miss out on this benefit simply because they did not know about it or forgot to tick the box. Check every year when filing your return.
The Trade-Offs
Partial non-resident status is not always beneficial. There are trade-offs to consider:
What You Lose
| Benefit | Impact |
|---|---|
| No Box 3 tax-free threshold | As a non-resident for Box 3, you do not get the €59,357 heffingsvrij vermogen. However, if your only Box 3 assets are foreign, this does not matter (they are exempt anyway). It matters if you have Dutch real estate. |
| Limited deductions | Non-residents cannot claim certain personal deductions. This affects Box 1 deductions like mortgage interest (on a Dutch home), charitable donations, and medical expenses. You may lose these deductions. |
| Qualifying non-resident taxpayer rules | If you earn 90%+ of your worldwide income in the Netherlands, you may still qualify as a "qualifying non-resident taxpayer" and reclaim some deductions. The rules are complex. |
| No tax partner allocation for Box 2/3 | As a non-resident for Box 2/3, you cannot use tax partner allocation for these boxes. |
When Partial Non-Resident Status Is NOT Worth It
- You have significant Dutch real estate but no foreign assets — you would lose the Box 3 threshold without gaining any exemption
- You rely on Box 1 deductions (mortgage interest, charitable donations) that would be lost or reduced
- You have no significant foreign assets — there is nothing to exempt
When It IS Worth It
- You have substantial foreign savings or investments (the more, the bigger the benefit)
- You own shares in foreign companies (5%+)
- You do not have a Dutch mortgage or do not rely on personal deductions
- The Box 3 tax saved on foreign assets exceeds the value of any lost deductions
Good to know
The calculation is not always straightforward. For people with both Dutch and foreign assets, or with significant deductions, it is worth running the numbers both ways (with and without partial non-resident status) to see which option results in lower total tax. The Belastingdienst's online filing tool supports this comparison.
Partial Non-Resident Status and Your Tax Partner
If you have a tax partner, partial non-resident status has implications:
- Your partner is not automatically partial non-resident — Each person's status is independent
- If your partner also has the 30% ruling, they can make their own election
- If your partner does not have the 30% ruling, they are a normal resident taxpayer and their worldwide assets are taxed in Box 2/3
- Tax partner allocation for Box 2/3 is restricted when you have partial non-resident status — you generally cannot shift assets between partners for these boxes
What Happens When the 30% Ruling Ends?
When your 30% ruling expires, you lose the ability to elect partial non-resident status. From that point:
- All worldwide assets are subject to Dutch Box 2 and Box 3 taxation
- Foreign bank accounts, investments, and property must be reported
- The transition can result in a significant increase in your tax bill
This is one of the most important financial transitions for expats. Plan ahead by:
- Understanding the full Box 3 impact of your foreign assets
- Considering whether to restructure assets before the ruling expires
- Building a financial buffer for the increased tax burden
Common Mistakes
- Not knowing about partial non-resident status — This is the most common mistake. Many 30% ruling holders never elect it because they are unaware of the option.
- Assuming it is automatic — You must actively elect it on your tax return every year.
- Electing it without calculating the trade-offs — If you have Dutch real estate and rely on mortgage interest deduction, the trade-off may not favor partial non-resident status.
- Not planning for the ruling's expiry — When the ruling ends, your foreign assets become taxable. The sudden increase in Box 3 tax can be a financial shock.
- Confusing "foreign" with "in foreign currency" — The determining factor is whether the asset is located abroad (foreign bank, foreign broker, foreign property), not whether it is denominated in euros or another currency. A euro-denominated account at a German bank is still a foreign asset.
What to Read Next
- Box 2 & Box 3 Impact — Detailed look at how the ruling affects Box 2 and Box 3
- When Your 30% Ruling Expires — Preparing for life after the ruling
- Box 3: Savings and Investments — How Box 3 taxation works in detail