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The New Work Costs Regime and Change of Employment Conditions

On 1 January 2011 a new tax regime will enter into force with regard to the payments and provisions employers can make to their employees. This new regime is known as the "work costs regime" and implies that employers may use a maximum of 1.4% of their total tax payroll sum per year to make untaxed payments and provisions (although the precise percentage is not yet sure, I will base myself on 1.4% in this article). This free spending limit is also known as the general fixed amount.

Employers are therefore no longer required to assess the payments and provisions on an individual basis; from now on they only have to render an account at employer's level. Payments and provisions exceeding the general fixed amount will be taxed to the employer with a final levy of 80%.

During the first three years, employers will have the choice between either applying the current regime or the new work costs regime. Without any action on the part of the employer, the new work costs regime will automatically become applicable. As the outcome may differ considerably per regime, employers will have to examine which regime is more favorable.

Most likely, employers will have to adjust their current arrangements with regard to payments and provisions at a certain time. Legally speaking this is not simple, because arrangements made cannot simply be changed unilaterally.

We have to distinguish two situations here: (i) the situation in which the employment agreement contains a unilateral alterations stipulation, and (ii) the situation in which it does not.

Even if an employment agreement contains a unilateral alterations stipulation, this still does not mean that the employer can simply change employment conditions. The employer will have to prove that he has such an important interest in the alteration that, according to standards of reasonableness and fairness, the interest of the employee that would be harmed by the alteration must be overridden.

If the employment agreement contains no unilateral alterations stipulation, the employer has to prove that maintaining the former situation in unmodified form would be unacceptable according to standards of reasonableness and fairness (the "test of unacceptability").

In summary, and ignoring several nuances, the following questions must always be answered: (i) Is there an important reason for the alteration? (ii) Can it be expected of an individual employee that he will agree? With regard to the latter question, this test is a little less strict if a unilateral alterations stipulation has been agreed.

In any case, the employer must always demonstrate on the basis of objective information why an alteration of employment conditions is necessary. A particular example of such information is financial information.

The next question to be answered on an individual level is whether the employee may be expected to agree to the alteration. At this stage the interests of the employer on the one hand will be weighed against the interests of the employee on the other hand. Important aspects in this respect are the level of the additional costs the alteration would involve for the employer and how much the employee would lose by it.

Case law shows that a unilateral change often does not stand up, and that courts tend to apply the test of unacceptability strictly. In practice, however, employers regularly alter their employment conditions unilaterally, and successfully. "Successfully" may take shape in successful legal proceedings, but also in the fact that employees accept the alteration and do not go to court. The employer may also influence this by proceeding carefully. In any case, good communication with the employees (or their representatives) and the Works Council is of great importance.

Pursuant to Section 27 of the Works Councils Act ("WOR"), the Works Council does not have a right to consent to the introduction of a work costs regime or the alteration of a reimbursement of expenses scheme. This may be different if the consent on this topic of the Works Council has been asked in the past, or if the Works Council has been promised that it will have a right to consent in this respect.

Even though the Works Council has no right to consent, it is good to inform it about the intended change and the reasons behind it. If the Works Council subsequently raises no objections, this will be an important - albeit not decisive - element in the weighing of interests in the employer's favor.

In conclusion, it is essential that an employer who wishes to alter employment conditions unilaterally as a result of the introduction of the work costs regime goes about it carefully and collects sufficient objective (financial) information that make clear that the employer has a great interest in the alteration. Furthermore, all these things should be communicated carefully and in good time to the Works Council and the employees. It is also necessary to look at the way the changes will work out at an individual level. If the changes appear to bring about a big deterioration for the employees (or an individual employee), it is recommendable to introduce a transition period or compensation scheme.

Observing the above-mentioned "standards of due care" will lead to it - although it cannot guarantee - that there is a bigger chance that the intended alteration of employment conditions will stand up. Moreover, these standards will increase acceptance among the staff.

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Itse Gerrits

Tel: +31 20 5506 689
E-mail: itse.gerrits@kvdl.nl

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