Holding Structure

The Pass-Through Salary Scheme: One Salary for Holding and Operating BV

Updated: 19 July 2026 Holdwise editorial team Pass-through salary Customary salary Holding

With the pass-through salary scheme (doorbetaaldloonregeling), you have one payroll, one payslip and one customary salary for your holding and operating company together. If you put a holding above your operating BV (besloten vennootschap, the Dutch private limited company), you formally work for two companies. In principle, the customary salary rule then applies to each company. At Holdwise, we keep this answer up to date and change it when the rules change.

Why the scheme exists

Outside this scheme, each company you work for would operate its own payroll and justify its own customary salary. This means double administration and discussion about how to split the salary. Under the pass-through salary scheme (article 32d of the Wage Tax Act), the operating BV pays the fee for your work directly to the holding. Only the holding puts you on the payroll. You get one payslip, one wage tax table and one customary salary for both companies.

The conditions in practice

You work for the operating BV from the holding. The holding owns a substantial interest in that BV. Both companies record the arrangement, usually in the management agreement. The operating BV pays a management fee to the holding. The holding pays your salary from this fee and withholds the payroll tax. In a new structure, this is arranged as standard at incorporation. In an existing structure, the companies record the arrangement and transfer the payroll to the holding.

You set the salary once. The payroll has to be done every month. See what we take over each month on payroll and administration for a Dutch BV.

What you get from the scheme

First, simplicity: one payroll where you would otherwise have two, and simple bookkeeping that keeps the annual accounts readable. Second, control over the customary salary: one amount across both companies, using the growth-phase agreement to keep that amount suitable. Third, a clear base for the rest of the payments: management fee, dividend through the holding structure and the loan from the BV each keep their own, defensible place. Source: Belastingdienst (pass-through salary scheme).

Last verified: 19 July 2026.

Free advice

Want our team to have a look?

We help you with your tax: salary, dividend and borrowing from your own company. Tell us where you stand or what you are planning. You get free advice on your next step.

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

Frequently asked questions

Do I need a separate salary in every BV as a DGA (director and major shareholder)? +

In principle, yes. The customary salary rule applies to each company. Under the pass-through salary scheme, only the holding operates your payroll. You then have one payslip and one customary salary for the holding and the operating BV together.

What is required to apply the pass-through salary scheme? +

You need three things. The holding has a substantial interest in the operating BV. You do your work from the holding. The arrangement is recorded, usually in the management agreement. The operating BV then pays a management fee, and the holding operates the payroll.

Does the scheme change the level of my salary? +

Under the scheme, the holding processes the payroll. The amount of your salary stays the same. You manage the customary salary as one amount. This also covers a lower salary where the rules allow it, for example when comparable work pays less.

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