Lenen van BV

Excessive Borrowing from a BV (Wet Excessief Lenen)

Updated: 19 July 2026 Netherlands 2026 English

Borrow more than €500,000 from your own BV (besloten vennootschap, the Dutch private limited company) and the excess is taxed in box 2. The Excessive Borrowing Act took effect on 1 January 2023 and carries substantial consequences for DGAs with high debts.

What is the Excessive Borrowing Act?

The Excessive Borrowing Act (Wet Excessief Lenen, in force since 1 January 2023) stops DGAs from postponing dividend indefinitely by borrowing from the BV instead of distributing. Above the threshold, the excess is taxed directly as income from a substantial interest.

Threshold and tax in 2026

The threshold is €500,000 (lowered from the initial €700,000 as of 2024). Any balance above it on 31 December 2026 is taxed as a deemed regular benefit in box 2:

First €68,843: 24.5%
Above that: 31%

Note: primary-residence loans from your own BV stay outside the count when they meet the mortgage-interest-deduction conditions.

The reference date

Debts are assessed on 31 December of each tax year. A balance above €500,000 on 31 December 2026 triggers tax on the excess.

Solutions when the debt runs too high

Distribute extra dividend and repay (box 2 applies to the dividend).
Repay from private means.
Structure home loans so they qualify as primary-residence debt.

Within the threshold, borrowing is precisely the steering instrument: see borrowing from your own BV and the tailored settlement via distributing dividend in 2026. The full playing field — salary, dividend, borrowing and structure in concert — sits on lowering your DGA salary. Last verified: 19 July 2026.

Terms on this page

Excessive borrowing rule: The rule that taxes loans from one’s own BV to the DGA above the statutory €500,000 threshold as deemed dividend in box 2. Below the threshold, borrowing from the BV stays a tax-neutral route.
Current account (rekening-courant): The running settlement account between DGA and BV on which small mutual amounts flow back and forth. Above a modest balance it calls for written terms and an arm’s-length interest rate.
Box 2: The box for income from a substantial interest: dividend and capital gains on a shareholding of five percent or more. Two brackets apply; the first bracket runs per person, which rewards spreading over years and partners.

All terms in the glossary →

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Part of Doing Business in the Netherlands — the complete 2026 guide.

Frequently Asked Questions

What if I have already borrowed more than €500,000? +

The excess is taxed in box 2. Repay the debt or distribute extra dividend (also box 2) to move back under the threshold.

Does my partner’s debt count too? +

Yes. Debts of your fiscal partner to the same BV count together with yours toward the €500,000 threshold.

Sources Belastingdienst · KVK · wetten.overheid.nl Last updated: 19 July 2026