Netherlands and Romania: Cross-Border Work and Tax (2026)

1In short

2The tax treaty

Treaty

NL–Romania tax treaty 1998

Employment income

Art. 15: taxed in the country where the work is done

183-day exception

The home country keeps the right only for a stay of 183 days or less in any 12-month period, paid by an employer from the home country and not borne by a branch in the other

Resident of both?

Art. 4(2): permanent home, then centre of vital interests, then habitual abode, then nationality

Dutch relief

Art. 24(2): exemption by reducing Dutch tax

Romania's relief

Art. 24(5)(a): credit for the Dutch tax, up to Romania's own tax on it

3Living in one country, working in the other

If you live in Romania and work for a Dutch employer (or the other way round), the employer's country taxes the pay for the days you work there, and your country of residence the pay for the days you work at home or elsewhere in that country. There is no official formula; in practice the salary is split by working days.

Example: €60,000 a year, 220 working days, of which 2 days a week at home (88 days).

Romania then relieves double tax on the Dutch part: it taxes the whole salary and deducts the Dutch tax, up to its own tax on that part.

4Moving from Romania to the Netherlands

From the day you live here, the Netherlands taxes you as a resident. Before that it taxes nothing, because you neither lived nor worked here. For your first year you file an M-form (migration return), due 1 July of the following year.

Romania uses the calendar year. You stay resident until your departure date if you then live abroad for more than 183 days in 12 months; file the residence questionnaire with ANAF before you leave.

With the 30% ruling the Dutch tax is lower. The M-form estimator and the cross-border calculator work out your own dates and salary.

5Social security

Within the EU you pay social security in one country only. A Dutch employer means Dutch social security, unless you live in Romania and do 25% or more of your work there: that indicates a substantial part, and then Romania's system applies (Regulation 883/2004 Art. 13; 987/2009 Art. 14(8)).

Working from home between 25% and 50% of the time? Under the EU framework agreement on cross-border telework (since 1 July 2023), employer and employee can jointly ask to stay in the employer's system, if Romania has signed it too; check with the SVB.

Posted to the Netherlands by an employer in Romania? Its social security can continue for up to 24 months with an A1 certificate (Art. 12).

6Checklist