DGA Salary via Holding: How Does the Management Fee Work?

Updated: 2026 DGA salary Holding Management fee

In a holding structure, the DGA salary is typically paid by the holding BV via a management fee charged to the operating company. Here is how this works in practice.

The management fee structure

In a standard holding structure:

The DGA has their employment contract with the holding BV (not the operating BV)
The holding BV charges a management fee to the operating BV for the DGA's services
The management fee is a deductible cost for the operating BV
The fee is income for the holding BV
The holding pays the DGA's salary and payroll taxes

What must the management fee cover?

The management fee must reflect the market value of the DGA's services to the operating company. At minimum, it must cover the DGA's salary plus payroll taxes plus any other employment costs. A reasonable profit margin for the holding's coordination services is also acceptable.

Market rate requirement

The management fee must be "at arm's length" — what an independent party would charge. The Tax Authority scrutinises this in holding structures. An unduly low fee is treated as a hidden dividend from the operating company to the holding; an unduly high fee may be treated as a non-deductible expense.

Practical example

DGA works full-time for the operating company. Customary salary: €56,000. Payroll tax: approximately €8,000. Management fee (minimum): €64,000 per year = €5,333 per month. If the DGA's market value is higher, the fee should reflect this.

Frequently Asked Questions

Does the holding BV need to pay Vpb on the management fee income? +

Yes. The management fee is taxable income for the holding at 19%/25.8% Vpb. After deducting the DGA's salary and payroll costs, the net profit in the holding is what is taxed.