The €500,000 line
The excessive-borrowing law measures all debts of the DGA (and partner) to the own companies each 31 December. Up to €500,000: fine. Above it, the excess is taxed as a deemed dividend in box 2 — the state simply treats over-borrowing as a distribution. One important carve-out: a qualifying loan for your own home sits outside the cap, provided it is properly documented and, for newer loans, secured with a registered mortgage right in favour of your BV (besloten vennootschap, the Dutch private limited company).
Why this is the famous lever
The combination is the point. A lower customary salary agreed with the tax authority for several years, combined with borrowing from your own BV up to €500,000, saves roughly €18,000 to €20,000 a year in tax and premiums: the salary stays small (little box 1 tax), the lifestyle is funded by the loan (zero tax at the moment of borrowing), and the profit meanwhile compounds at 19% instead of being consumed at top rates. Dividend later settles the score, in years and brackets you choose.
The paperwork that keeps it real
- A written loan agreement with businesslike terms: market-level interest, a repayment schedule, security where a bank would ask for it.
- Interest actually paid or accrued — it is company income, taxed as profit, so the money circles inside your own system.
- The 31 December photo: know your total shareholder debt before year-end, and repay or distribute deliberately if the line approaches.
Where it stops being clever
A loan consumed with zero repayment intent is a dividend wearing a costume, and inspectors undress costumes for a living. The instrument works for people who run it like a bank would — which is exactly the discipline the rest of this programme builds. Full legal detail: the excessive borrowing rules; the home version: buying a home versus investing.
Read next
This question continues in creators/questions and in creators/where-your-company-is-taxed.