Moving a freelancer onto payroll: the 30% ruling angle

You have been working with a contractor and it is time to bring them onto the payroll. The 30% ruling (becoming the 27% ruling from 2027) can still apply, but converting a freelance relationship into employment surfaces a specific set of questions that a normal international hire does not. This guide walks HR through what to check before drafting the employment contract.

What actually changes when a freelancer becomes an employee

For the ruling, what matters is the employment relationship. A ZZP contract with your company is not employment, and the ruling attaches to a specific employment. So the ruling clock starts at the first working day of the new employment, and the eligibility test looks at the situation immediately before that date.

That means the freelance period is not disqualifying by itself. What matters is where the freelancer lived and worked in the 24 months before the new employment starts.

The incoming-employee condition, applied to this case

Two tests do the heavy lifting:

• Recruited from abroad. The employee must be hired from outside the Netherlands. If the freelancer has been living in the Netherlands and doing the work here, this test usually breaks the case.
• Distance rule. The employee lived more than 150 km from the Dutch border for most of the 24 months before the first working day.

If the freelancer was based abroad and invoicing your Dutch entity from there, the case can look a lot like a normal international hire. If they moved to the Netherlands during the freelance period, the analysis gets more careful.

The 24-month lookback and prior work in NL

A pattern we see often: a candidate did a Dutch master's, freelanced through their studies or in the year after, and now you want to hire them. Freelance income during studies rarely disqualifies on its own. Freelance work inside NL in the 24 months before start can. The line depends on how the activity is documented, how long the person had been physically in NL, and whether the master's graduate exception is available.

Prior stays or work in NL in the 25 years before start can also deduct from the term, even when the ruling itself is granted. Worth flagging on the case sheet.

Salary norms to check against

The offer needs to clear the salary norm for the year the ruling starts:

• 2026: €48,013 taxable after the tax-free part for standard applicants, €36,497 for under-30 holders of a Dutch or equivalent master's degree.
• 2027: €50,436 and €38,338.

Freelance day rates translate poorly to base salary. Do the arithmetic before the offer, not after.

What HR should check before drafting the contract

• Where the freelancer lived and worked in the 24 months before the planned start date.
• Whether they were on a Dutch address (BRP registration) during the freelance period.
• KvK registration history and the nature of the work invoiced.
• Whether the under-30 master's route is available as a fallback if standard salary is tight.
• Contract clause reserves the tax-free allowance separately from taxable salary.
• Application filed within 4 months of the first working day for retroactive effect.

Get this evaluated before you draft the contract, not after signature.