How it works
A DGA can borrow from their own BV, for example for a house, an investment or a private purchase. Since 2023 there is a legal limit. On 31 December, the tax authority adds up all loans from the BV to the DGA, their partner and, in some cases, their children. The amount above €500,000 is taxed in box 2 as a deemed dividend.
A mortgage loan for the house the DGA lives in is left out of the total. The condition is that the BV has a registered mortgage on that house. For loans from before 2023, a transition rule applies to the mortgage part.
Below the limit, the normal rules apply. You need a written agreement, a market interest rate and, for larger amounts, security. If you repay part of the loan, the amount above the limit is lower in a later year. The tax paid on the deemed dividend is credited when the DGA repays the loan and the BV pays a dividend.
For a DGA who relocates abroad, the rule applies at the moment of emigration and through the conservation assessment. Check the loan balance early, before you relocate abroad.
Example
A DGA has borrowed €700,000 from his holding for investments, all of it unsecured. On 31 December the excess is €200,000. He pays box 2 tax on €200,000 as deemed dividend. In the next year he repays €200,000. His loans are then back at the limit of €500,000.
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 loans to my children count?
Loans from the BV to a child count for the part above €500,000 per child. That part is added to the loans of the DGA. Loans to a partner count in full, together with the DGA’s own loans.
Is the €500,000 per year?
It is the balance on 31 December, tested every year. If you repay enough before the end of the year to get below the limit, you avoid the deemed dividend for that year.
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.
Want our team to have a look?
We help entrepreneurs and international companies with their company in the Netherlands and Europe. Tell us about your situation or your plans. Our team looks at it and replies with the next step.