The four required elements

  1. A written agreement: amount, rate, term, repayment schedule, any collateral. Absent paperwork invites the deemed-dividend label.
  2. An arm’s-length rate: what an independent lender would charge — typically 4–6% depending on term and security; benchmarks per type: interest on a BV loan.
  3. A realistic repayment path: a loan that only ever grows reads as a distribution in instalments.
  4. Room at the BV: the company must be able to miss the money while its own obligations stay comfortable.

The €500,000 frame

All loans together (qualifying primary-residence debt excluded) stay at or below €500,000 on 31 December — the excess is taxed as deemed dividend in box 2. Inside the frame, the loan is precisely the steering instrument of the DGA mix: withdrawing at 0% now, settling through dividend in years with bracket room. The full rulebook: DGA borrowing from their own BV; the annual mechanics: excessive borrowing 2026. Last verified: 19 July 2026.