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. The pass-through payroll rule solves that: one company, usually the holding, pays the full salary and the others pay a management fee to it.
The condition is that the other companies pay their part of the salary to the paying company and that the DGA is formally employed by that company. The tax authority confirms the arrangement on request; in most holding structures it applies on its own, because the DGA is on the payroll of the holding only.
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 rule keeps the payroll in one place too; where the salary is taxed follows the 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. One payroll, one payslip, one salary test on €75,000.
The figures
All 2026 figures: Netherlands tax rates 2026 · the 2027 figures: Netherlands tax rates 2027.
Questions people ask
Do I need the tax authority’s approval?
The rule can be applied when the conditions are met; an approval is available on request and gives certainty in an audit.
Can the operating company be the one that pays the salary?
Yes. The rule works in either direction; most groups choose the holding so that the operating company keeps only its own staff on the payroll.
Holdwise, Hoofddorp. Definition and explanation maintained with the Dutch and German glossaries; figures from the central rates source, year 2026. Updated 16 September 2026.
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