How it works
A DGA can borrow from their own BV: for a house, an investment or a private purchase. Since 2023 the law sets a 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, as long as the BV holds a registered mortgage on that house. Loans that were already there before 2023 fall under a transition rule for the mortgage part.
Below the limit the normal rules apply: the loan needs a written agreement, a market interest rate and, for larger amounts, security. Repaying part of the loan lowers the amount above the limit in a later year, and tax paid on the deemed dividend is credited when the loan is really repaid and dividend is paid.
For a DGA who lives abroad the rule applies at the moment of emigration and through the conservation assessment. That makes the loan balance one of the first things to check before a move.
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, and the limit is back to €500,000 for future loans.
The figures
All 2026 figures: Netherlands tax rates 2026 · the 2027 figures: Netherlands tax rates 2027.
Questions people ask
Do loans to my children count?
Loans from the BV to children count for the part above €500,000 per child, attributed to the DGA. Loans to a partner count in full with the DGA’s own loans.
Is the €500,000 per year?
It is a balance on 31 December, tested every year. Repaying below the limit before the year end avoids the deemed dividend for that year.
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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