How it works
A DGA with a holding and one or more operating companies formally works for all of them. Under the general rules, each company would need its own payroll and its own customary salary. Under the pass-through payroll rule, one company pays the full salary. This is usually the holding. The other companies pay it a management fee.
The other companies must pay their part of the salary to the paying company. The DGA must also be formally employed by that company. On request, the tax authority confirms the arrangement. The rule applies only when these conditions are met. A holding structure alone is insufficient.
The customary salary is then tested once, for the whole group, on the total work the DGA does. That total can be higher than for one company, because the DGA works for several.
For a DGA who lives abroad, the payroll is also in one company. Where the salary is taxed depends on the tax treaty and the place of work.
Example
A DGA owns a holding with two operating companies. The holding employs her at €75,000. Each operating company pays the holding a management fee for her work. She has one payroll and one payslip, and the salary test is done once, on €75,000.
The figures
Every rate for 2026 is listed in Netherlands tax rates 2026, and the figures for 2027 are in Netherlands tax rates 2027.
Questions people ask
Do I need the tax authority’s approval?
You can apply the rule when the conditions are met. On request, the tax authority gives an approval. With this approval, you are sure of your position in an audit.
Can the operating company be the one that pays the salary?
Yes. Either company can pay the salary. Most groups choose the holding, so that the operating company has only its own staff on the payroll.
Holdwise, Hoofddorp. We keep this definition in line with our Dutch and German glossaries, and the figures are those for the tax year 2026. Updated 30 September 2026.
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