Dutch tax optimization for BV owners

The three layers

Combined, profit that travels the full route — corporate tax first, then box 2 — lands around 38–40% total. Every euro that stays inside the structure compounds at the 19% layer instead; the strategy below is about choosing when each euro crosses each line. All figures stand on the figures page.

1. Set the salary at what the phase asks

The customary salary norm is €58.000 for 2026 — and in a growth or startup phase, a lower customary salary can be agreed with the tax authority: the norm follows what the company can reasonably carry, and a written agreement settles it upfront. Every euro moved out of box 1 at marginal rates up to 49,5% and left at the 19% corporate layer is the single largest lever a DGA holds. The DGA salary calculator shows your numbers; the customary salary guide and the startup salary guide walk the agreement route.

2. Take liquidity through the borrowing route

Private spending power comes from the structure in two ways: distribute and pay box 2 now, or borrow from your own BV at a business-like interest rate and keep the capital compounding at corporate rates. The excessive borrowing measure draws the line at €500,000 in current-account and other debts — financing of the own home stays outside it — which leaves substantial room for a house extension, a car or an investment, documented in a loan agreement. The excessive borrowing guide holds the mechanics and the current-account guide the paperwork. Combined with a fitting salary level, this route is where the €18,000–€20,000 per year typically materialises.

3. Time the dividend inside the bracket

Box 2 has two rates: 24,5% up to €68.843 per person per year, 31% above. Distributions planned per calendar year — and doubled with a fiscal partner — stay inside the low bracket; a single large distribution crosses into the high one. The dividend guide and the timing guide set out the mechanics, including the distribution test the board signs off.

4. Put the holding layer under it

A holding structure makes the whole strategy durable: under the participation exemption, dividends and sale gains on holdings of 5% or more arrive at the holding untaxed. Profit moves out of the operating company clean, accumulates apart from trading risk, and the box 2 moment stays yours to choose — including at a future sale, where the holding receives the price and box 2 falls only on what you take out privately. What a holding company is explains the concept from the ground up.

5. Use the rulings the system offers

Staff you recruit from abroad can qualify for the 30% ruling, innovation profit can land in the innovation box at a reduced rate, and R&D hours can carry WBSO relief on payroll tax. Each ruling is a written position — the same principle as the salary agreement: settle it upfront, in writing, on the 2026 figures.

This page describes the general strategy for 2026; what it means for your situation follows from a personal conversation.