Dutch tax enforcement on false self-employment is active while a new Zelfstandigenwet is being prepared. Current assignments remain subject to existing rules. How work is managed today can create payroll-tax exposure later.
Why this matters
A signed contract does not settle a worker’s status. The full relationship matters, including instructions, hours, replacement, pricing and commercial risk. If daily work resembles employment, payroll-tax corrections may follow. Assessments can generally cover work performed since 1 January 2025. Existing approved model agreements remain useful only when the work follows their terms.
Example
A specialist was hired for a project. The work continues, and the specialist now attends staff meetings. A manager sets weekly priorities and approves time off. The specialist uses company systems and cannot realistically send a replacement. The contract still describes an independent project, but the work record now shows a recurring staff role.
XTROVERSO tips
- List recurring assignments. Record each zzp engagement, including work arranged directly by managers. Note the scope, rate, start date and planned end date.
- Compare the contract with the work. Check who sets hours, assigns tasks and approves changes. Review replacement rights, systems access and commercial risk.
- Keep one usable file. Store the contract, invoices, project plans, key emails and review notes together. The records should tell the same story.
- Review changes during the assignment. Set a review when the scope expands, the project is extended or the contractor joins a fixed rota.
- Price another staffing route. Compare the contractor budget with payroll, agency fees and other employment costs. Do this before a staffing gap forces a rushed choice.
Need a clear review of a zzp arrangement before the next contract, invoice or planning cycle? Let’s discuss the working facts
The data, sourcing, and analysis behind this article were conducted by Paolo Maria Pavan. AI was not used to identify sources, build the factual basis, or produce the analytical judgment contained here. AI was used only as a drafting aid. The final English text was personally reviewed, edited, and approved by Paolo Maria Pavan before publication.
References
- Rijksoverheid — Troonrede 2026 en aangekondigde Zelfstandigenwet
- Belastingdienst — Handhaving arbeidsrelaties
- Belastingdienst — Geen nieuwe modelovereenkomsten meer
- Belastingdienst — Beoordeel samen uw arbeidsrelatie
- Rechtspraak — Hoge Raad, ECLI:NL:HR:2023:443
- Rijksoverheid — Beleidsbesluit over zzp’ers en opdrachtgevers
- CBS — Arbeidsmarkt, tweede kwartaal 2026


