Your Dutch BV before 31 December 2026: what you can decide now
The Tax Plan 2027 is a package of bills. Most of it takes effect on 1 January 2027 once both chambers of parliament adopt it. Four points in it touch every owner of a Dutch BV, whether you live in the Netherlands or abroad: the box 2 rate, the limit for loans from your own company, the step-up for a company that relocates here, and the value of your private assets on 1 January 2027.
Ask about your situationIn 2026 the law is known: dividend from your BV is taxed in box 2 at 24.5% up to €68,843 per person and 31% above that. For 2027 the bill keeps 24.5% up to €69,703 and 31% above. On 29 September 2026 the cabinet announced a lower high rate of 29.2% for four years, 2027 to 2030. That rate is an announcement: on 27 October 2026 it is outside every bill before the House of Representatives.
The same letter announces a lower limit for loans from your own BV: from €500,000 down to €100,000 in five steps of €80,000, the first step in 2027. Corporate tax stays at 19% and 25.8%. The step-up for a company that transfers its seat to the Netherlands is in bill 37023 for 1 January 2027. The decisions for you: use the 2026 low band for dividend, plan a large dividend for 2027 to 2030 if 29.2% passes, bring a shareholder loan below the coming limits, choose 2027 for a seat transfer, and decide where your private money is on 1 January 2027.
Tell us what you make or sell, where your company is and what you plan in Europe. Our team looks at it and replies with the steps and the dates that apply to you.
2026 versus 2027 (bill): the figures for a BV owner
| Item | 2026 (law) | 2027 (bill or announcement) | Status on 27 October 2026 |
|---|---|---|---|
| Box 2, first band | 24.5% up to €68,843 per person | 24.5% up to €69,703 per person | Bill (Tax Plan 2027, key figures table) |
| Box 2, high rate | 31% | 31% in the bill; 29.2% announced for 2027 to 2030 | Announced in the cabinet letter of 29 September 2026; still to be put into a bill |
| Loans from your own BV | Debts above €500,000 on 31 December are taxed in box 2 as dividend | Limit down to €100,000 in five steps of €80,000 from 2027; home loans with a mortgage stay excluded | Announced in the cabinet letter of 29 September 2026; still to be put into a bill |
| Corporate tax | 19% up to €200,000, 25.8% above | 19% up to €200,000, 25.8% above | Unchanged in the bill |
| Innovation box, flat amount | Up to €25,000 of profit at the flat rate | Up to €100,000, for financial years from 1 January 2027 | Bill (37022, article 12bd Corporate Income Tax Act) |
| Step-up at a seat transfer to the Netherlands | Historical acquisition price | Acquisition price set at market value on the day the Dutch tax liability starts | Bill (37023, article 7.6 Income Tax Act 2001), 1 January 2027 |
| Employee stock options at start-ups | Taxed when the shares become tradable | 65% of the benefit counts as wage, taxed at the sale of the shares, with a choice for earlier taxation; the company needs a decision from the Netherlands Enterprise Agency (RVO) | Separate bill, intended for 1 January 2027 |
| Expat ruling | 30% of the salary tax-free | 27% of the salary tax-free; 30% stays for five years for rulings that started before 2024 | Law, adopted |
| Box 3, tax-free amount | €59,357 per person | €60,098 in the bill; €30,846 announced on 29 September 2026 | Bill; the lower amount is announced and goes into a supplementary bill |
The package was submitted on 15 September 2026 as the Tax Plan 2027 (37022), the Other Tax Measures 2027 (37023), the bill on start-ups and scale-ups and a bill on safe harbours for the minimum tax. The House of Representatives debates the package in plenary in week 45 of 2026 and votes after that debate. The Senate follows in December. The cabinet wants the package and the supplementary bill on box 3 adopted before 31 December 2026. Two memoranda of amendment, of 14 and 20 October 2026, change other parts of the bill; the 29.2% rate and the lower borrowing limit are still outside them.
Decision 1: the 2026 low band for dividend
In 2026, each shareholder pays 24.5% on the first €68,843 of dividend. With a tax partner, each of you has that band, so a couple takes out €137,686 at 24.5%. A dividend above the band is taxed at 31% in 2026. The band is a yearly amount: what you leave unused in 2026 is gone on 1 January 2027.
The BV needs profit reserves and a solvency check before it pays dividend. The board signs the resolution and the BV files the dividend tax return within one month. Our profit calculator shows what stays after corporate tax and box 2.
Tell us what you make or sell, where your company is and what you plan in Europe. Our team looks at it and replies with the steps and the dates that apply to you.
Decision 2: a large dividend in 2027 to 2030 at 29.2%
The cabinet letter of 29 September 2026 lowers the high rate in box 2 by 1.8 points to 29.2% from 2027, for four years. The stated reason is to encourage owners to take capital out of their companies. On a dividend of €300,000 above the first band, the difference is €5,400: €93,000 at 31% in 2026 against €87,600 at 29.2% in 2027.
The rate is an announcement until a bill contains it. If it passes, 2027 to 2030 is the window for a large dividend, a sale of your shares to your own holding, or the clean-up of a shareholder loan. If it fails, 2027 looks like 2026. The decision for December 2026: take the low band now, and keep the large amount for 2027 once the Senate has voted. See the owner-director in 2027 for the mix of salary and dividend.
Decision 3: a shareholder loan above the coming limits
Under current law, debts to your own BV above €500,000 on 31 December (you and your partner together, home loans with a mortgage excluded) are taxed in box 2 as a deemed dividend. The cabinet letter announces that this limit goes to €100,000 in five steps of €80,000, starting in 2027. Five steps of €80,000 from €500,000 give €420,000, €340,000, €260,000, €180,000 and €100,000. The years for each step come with the bill.
For 31 December 2026 the limit is €500,000. An owner who financed property or investments through the BV has three routes: repay from private funds, refinance with a bank, or pay a dividend and settle the loan with it. The dividend route costs box 2 tax, at 29.2% in 2027 to 2030 if the announced rate passes. Start the bank conversation now: a refinancing takes months. See borrowing from your own BV.
Decision 4: relocate the company seat in 2027, with the step-up
Bill 37023 changes article 7.6 of the Income Tax Act 2001. When a foreign company transfers its effective management to the Netherlands and its foreign owner becomes liable to Dutch tax on the shares, the acquisition price is set at the market value on that day. The Netherlands then taxes only the growth after the transfer. The exception: a shareholder who was already liable to Dutch tax for these shares keeps the old price.
The rule applies when the Dutch tax liability starts on or after 1 January 2027. A transfer that takes effect in 2026 falls under the current text, with the historical acquisition price. For a company with large accumulated value, the transfer date is therefore in 2027, after the Senate vote. The full rule, the example and the steps are on relocating a company to the Netherlands in 2027.
Decision 5: where your private money is on 1 January 2027
Box 3 taxes private assets on their value on 1 January. For 2026 the tax-free amount is €59,357 per person, the rate is 36% and the deemed return is 6.00% for investments, 1.28% for bank balances and 2.70% for debts (the last two provisional). For 2027 the bill has €60,098; the cabinet letter announces €30,846 and a deemed return on investments 1.5 points higher. From 2028 the cabinet proposes a capital gains tax on shares, bonds and other financial instruments, taxed on sale. All of that is proposal.
Money inside your holding BV is outside box 3. The BV pays corporate tax on the real result, and you pay box 2 only when you take the money out. Money that goes into your holding before 1 January 2027 and stays there is outside box 3 on that date. Our box 3 or BV calculator compares both for your amount. For owners abroad: box 3 covers Dutch real estate only; see the Dutch wealth tax for foreign residents.
One Dutch company, many roles
Your own Dutch BV is the company that pays the dividend, has the shareholder loan on its books, receives the step-up and keeps your investments outside box 3. One holding above an operating company adds the participation exemption: the holding receives dividend and sale proceeds from the operating company free of corporate tax. The company is yours, the address is yours and the directors are yours; we set the company up and keep its books.
Prices: your Dutch company (BV) from €2,950 excl. VAT, and a holding with an operating company from €4,950 excl. VAT. Partner work has its own price, which you see first. See the Dutch holding structure.
Who does what
- You decide the dividend, the loan, the transfer date and where your private money is on 1 January 2027. You sign the shareholder resolution and the bank papers.
- We work out the figures for your own situation in writing, prepare the dividend resolution and the dividend tax return, keep the books of the BV and file the corporate tax return. We follow the bills through both chambers and tell you when a figure changes.
- Partners do the specialist work: the notary for a share transfer or a seat transfer, a valuer for the market value on the transfer date, a bank for the refinancing of a shareholder loan. We choose the partner with you, after you ask for it.
The salary calculator for owner-directors gives the customary salary and the tax on it. Want our team to have a look?
Sources
- Tax Administration, box 2 rates 2026: belastingdienst.nl (2026).
- Tax Administration, corporate tax rates 2024 to 2026: belastingdienst.nl (2026).
- Tax Administration, loans to the shareholder above €500,000: belastingdienst.nl (2026).
- Tax Administration, box 3 calculation 2026: belastingdienst.nl (2026).
- Key figures table 2027 (fiscale sleuteltabel), Ministry of Finance: rijksoverheid.nl (15 September 2026).
- Tax Plan 2027 package, all bills and documents: rijksoverheid.nl (15 September 2026); bill Tax Plan 2027, article 12bd innovation box: rijksoverheid.nl.
- Bill Other Tax Measures 2027 (37023), article 7.6 Income Tax Act 2001 (step-up): rijksoverheid.nl (15 September 2026).
- Bill on tax incentives for start-ups and scale-ups, article 10b Wage Tax Act: rijksoverheid.nl (15 September 2026).
- Cabinet letter of 29 September 2026 on box 2 (29.2%), loans from your own BV and box 3: eerstekamer.nl.
- Memorandum of amendment of 14 October 2026 (37022, nr. 17) and second memorandum of 20 October 2026 (37022, nr. 22): eerstekamer.nl.
- House of Representatives, progress of bill 37022: tweedekamer.nl (27 October 2026).
- Senate, bill 36748 on box 3, committee decision of 13 October 2026: eerstekamer.nl.
- Netherlands Enterprise Agency (RVO), expat ruling 27% from 2027, law adopted: ondernemersplein.overheid.nl.
Last reviewed: 27 October 2026. Based on the bills of 15 September 2026, the cabinet letter of 29 September 2026 and the memoranda of amendment of 14 and 20 October 2026, as published on the official sites named above. Every 2027 figure is a bill or an announcement until both chambers have voted.
Common questions
Which of the five decisions apply to you?
Tell us where you live, what the BV owns and whether there is a shareholder loan. You receive advice on the order of the steps before 31 December 2026.
Related guides
More for owners of a Dutch BV on the way to 2027.