The €500,000 limit
The excessive-borrowing law applies to the DGA (a director who also owns the company) and their partner. The Tax Administration adds up all their debts to their own companies on 31 December of each year. In 2026, debts up to €500,000 are allowed. The cabinet proposes to lower this limit step by step: to €420,000 in 2027, €340,000 in 2028, €260,000 in 2029, €180,000 in 2030 and €100,000 in 2031. This is in a letter to parliament of 29 September 2026 and is still only a proposal. Above that, the excess counts as a deemed dividend in box 2 (the tax band for income from a substantial shareholding). It is taxed as if it had been paid out. A qualifying loan for your own home is excluded from the limit, if the loan is properly documented. Newer home loans also need a registered mortgage right in favour of your BV (besloten vennootschap, a Dutch private limited company).
Why a loan and a lower salary work well together
A lower customary salary is allowed if comparable work pays less, or for up to three years while a new BV is still unable to pay the full salary. You can also borrow up to €500,000 from your own BV. The lower salary is what saves tax. At €36,000 in place of €58,000, you keep about €7,100 a year more. After a later dividend, about €2,800 of that remains. The loan gives you access to money, but your tax stays the same. Calculate it with your own figures. With a low salary, you pay little box 1 tax (tax on income from work). Borrowing the money you live on is tax free. The profit in the company is taxed at 19% on the first €200,000 and 25.8% above that, in place of the top personal rate. Later, you pay the tax through a dividend, in the years and brackets you choose.
The paperwork you need
- A written loan agreement with businesslike terms: market-level interest, a repayment schedule, security where a bank would ask for it.
- Interest paid or accrued counts as company income and is taxed as profit. Either way, you pay the interest to your own company.
- Check your total shareholder debt before 31 December. If you are close to the limit, repay part of the loan or pay out a dividend.
When a loan causes problems
If you spend a loan and lack a real intention to repay it, it counts in practice as a dividend. Tax inspectors check for this. Treat the loan with the same discipline as a bank would. See the excessive borrowing rules for the legal details. For a loan for your home, see buying a home versus investing.
Related articles
See also all creator money questions and where your company is taxed.