🇫🇷 COUNTRY A France VS 🇳🇱 COUNTRY B Netherlands

Both offer a 30% salary exclusion, but they differ meaningfully: Duration: France offers 8 years; the Netherlands offers 5 years (cut from 8 years on 1 January 2019). Simplicity: the Dutch 30% ruling is employer-administered — the employer withholds 30% less tax automatically. France's impatriate regime requires annual tax return claims. Scope: Partial non-resident status for Box 2/3 income was abolished from 1 January 2025. Only workers who already held the 30% ruling before 2024 (applied for the last 2023 wage period) can still elect it, and only through tax year 2026 — the option ends entirely from 1 January 2027. New 30% ruling holders from 2024 onward no longer have this election and are taxed on worldwide Box 2/3 income like other Dutch residents. France's regime exempts 30% of salary plus all foreign-source passive income not remitted to France. Application: Dutch ruling requires application to the Dutch tax authorities within 4 months of starting the job; French regime is claimed on the first French tax return. For most highly-paid corporate relocations: the Netherlands wins on simplicity, though the Box 2/3 partial non-resident election is now closed to new arrivals (grandfathered only through 2026 for pre-2024 ruling holders). For entrepreneurs and those with significant foreign assets: France's 8-year duration and assurance-vie give a long-term edge.

The Dutch tax system divides income into three boxes: Box 1 (employment and business income, 35.75%/37.56%/49.5% in 2026 including national insurance); Box 2 (substantial shareholdings ≥5%, 24.5%/31%); Box 3 (savings and investments — all other assets minus liabilities). Box 3 does not tax actual returns — instead it imposes a deemed return. For 2026: cash savings: deemed return 1.28% (provisional); other investments: deemed return 6.00%; debt: deemed deduction 2.70% (provisional). The combined deemed return applies to net assets above the threshold (€59,357 single; €118,714 for fiscal partners), taxed at a flat 36%. The Dutch Supreme Court ruled in December 2021 that Box 3 violated fundamental rights (privacy and property protection in ECHR) where actual returns were lower than the deemed return. Since then, a transitional system applies, and the Dutch government plans a 'real return' Box 3 to replace it from 1 January 2028 (the bill has not yet passed the Eerste Kamer). For 2026, the transitional rules still apply. Planning implication: Box 3 as currently structured is conservative for cash but potentially onerous for investment portfolios underperforming the deemed return.

It depends on the asset type and holding period. Dividends: France imposes PFU 30% (prélèvement forfaitaire unique = 12.8% income tax + 17.2% CSG/CRDS); Netherlands imposes 15% dividend withholding at source, then Box 3 notional return system. Capital gains on shares: France: 30% PFU on realised gains. Netherlands: no CGT on ordinary shareholdings in Box 3 — gains are included in the deemed return calculation instead. Long-term savings in France's assurance-vie: 7.5% after 8 years — clearly the winner for long-term portfolio income. Dutch 30% ruling holders who already held the ruling before 2024 can still elect partial non-resident status through tax year 2026, excluding foreign Box 3 assets from Dutch tax during that window — but this election was abolished for new ruling holders from 1 January 2025 and ends for the grandfathered group too from 1 January 2027. For a Dutch 30% ruling holder in the grandfathered group with €2M in foreign stocks: Box 3 tax = €0 through 2026, but those foreign assets become taxable under Box 3 from 2027 once the transitional election ends. For a French impatriate with €2M: assurance-vie after 8 years = 7.5% on gains — excellent. Without special status: France's PFU at 30% and Netherlands' effective Box 3 rate at 36% are similar.