Prinsjesdag 2025 for you as a DGA with your BV
- Jenifer Benton
- Oct 8
- 12 min read
Because the Schoof I Cabinet fell on June 3, 2025, elections for a new House of Representatives will be held on October 29. Due to this situation, the cabinet for the transition produced a relatively ‘policy-poor’ 2026 Budget Memorandum. Nevertheless, it is fair to say that the accompanying 2026 Tax Plan contains a number of measures that will directly affect you as a director and major shareholder (DGA) of your own private limited company. Sometimes to your advantage, but often to your disadvantage.
As it does every year, the NOAB has shared an important update on this information and we are happy to provide you with a concise summary. Please do not hesitate to contact us to discuss how these changes will impact your situation.
This overview covers the most important measures that apply to you as a DGA. Please note that these are only matters that are particularly important for DGAs with their own private limited company. Apart from these measures, many more tax changes have been announced. In addition, measures were also announced last year that will take effect in 2026 (or even later).
This overview is not set in stone. It is based on the content of the 2026 Tax Plan, as published on September 16, 2025. The final details of the plans may still change in the final legislation. This is even likely, as the new House of Representatives may have a different opinion.
Content of the qrticle
Box 2-levy
The box 2 levy has been unstable in recent years. Until 2023, it was simply a single rate of 25% for dividends received and capital gains on shares from your own private limited company, but from 2024 onwards, the rate will be differentiated into two brackets.
Schematically, the box 2 levy is as follows:
Please note that for the first time since 2025, the general tax credit (AHK) will be reduced by box 2 income. This also applies to the year 2026, and then for income up to €79,137. After that, you will no longer receive a general tax reduction.
What does this mean if, for example, you are a DGA with a salary of €56,000? In that case, the effective box 2 rate is:
It is noteworthy that this rate is the same as the high box 2 rate, at 31%. From a tax perspective, paying dividends is only attractive if you and/or your partner's income exceeds €79,412.
But be aware that paying dividends can also affect other of tax credits, allowances, and other income-related regulations. Many regulations in the Netherlands are income-related. The higher your income, the less you can benefit from these regulations. Paying dividends is a form of income, which means that you may be less able to benefit from these regulations.
That's why it is wise to consult with us before you decide to pay dividends from your own BV, so that we can draw up a plan of action together. If you then decide to pay dividends, we will determine the optimal dividend and the best time to pay it. This is especially important if you want to make a larger purchase with money from your own BV.
Corporate income tax
Corporate income tax will remain unchanged in the coming year. The first bracket of €200,000 will continue to be taxed at 19%, with the remainder taxed at 25.8%. This is the fourth consecutive year that corporate income tax rates have remained unchanged, which is unique in the current fiscal climate.
Because corporate income tax has two brackets, it is important for companies with multiple subsidiaries to carefully consider the profits in those subsidiaries. We are happy to help you with this. Here is an example:
A holding company with a profit of €50,000 and an operating company with a profit of €350,000. Together, they make a profit of €400,000. However, part of the operating company's profit is taxed at 25.8%, while the holding company still has ‘room’ in the first bracket of 19%. In this case, we could distribute the profit. This makes it relatively easy to save on corporate income tax. In the above example, up to a maximum of €13,600.
Integral tariff
When you have made a profit in your private limited company, you first pay corporate income tax. If you then distribute that net profit as a dividend, you pay dividend box 2 tax-levy on it. Both taxes are progressive, and the sum of these is called the integral tariff. Here is an example:
Someone who spreads their profits, ensuring that their corporate income tax does not exceed 19% and regularly pays dividends so that their box 2 tax does not exceed 24.5%, ultimately pays only 38.845% in total tax.
This example shows that there is a clear difference between someone who distributes their profits effectively and also pays regular dividends, and someone who pays the maximum rate. This difference is almost 10%! That is why it is important to consult with us to draw up a good plan of action together.
Excessive lending
This is not a new measure in itself. If a DGA (together with his or her fiscal partner) borrows too much from his or her own BV, the excess amount is classified as a dividend. From December 31, 2024, this limit will be €500,000.
If you still want or need to consider borrowing more than €500,000 from your own BV, we strongly recommend that you talk to us first to see what the best options are for avoiding unnecessary extra costs.
DGA salary
An increase in the DGA salary is expected to be implemented from January 1, 2026. The official amount of the increase will not be announced until the end of this year, but the current expectation is an increase in the minimum full-time salary from €56,000 to €57,000.
The topic of DGA salary is complex. However, because an increase in the DGA salary affects other income-related benefits, this salary increase may have other unwanted consequences. Some people may lose benefits as a result. It is therefore a good idea to be prepared for the coming year. We are happy to help you understand how this increase may impact your personal situation.
Act amending tax business succession facilities 2025
As a DGA, under certain conditions, you can transfer your company in a tax-efficient manner to someone else, such as your own child, through a share transaction. If the price you charge for your company is lower than the current value of your BV, this is considered a gift. In this case, the Business Succession regulation (BOR) applies, which means that no or almost no gift tax is to be paid.
In addition, the box 2 claim may come up, because you are disposing of your shares in your own BV. In that case, you can transfer this to the business successor via the transfer regulation (DSR).
The BOR and DSR will also change as of January 1, 2026. That's why it is important to carefully consider business succession, and especially its planning. This only applies if you transfer the BV at a low price or donate it in its entirety, and mainly if you do so to your children. This arrangement does not apply if you simply sell your BV.
To make use of this regulation, it is important to start as early as possible and in the correct manner, as this is a complex procedure and it can take a few years before your BV is ready for the business succession facilities.
Here is a summary of the most important changes for DGA's with their own BV:
Removal of the business succession facilities for business assets that are (partly) leased or used for both private and business purposes;
The introduction of an age limit: the successor must be at least 21 years old;
The period during which the successor must continue the business has been reduced from five to three years for transfers from January 1, 2025;
From 2026, only ordinary shares will qualify for the business succession facilities, to a lesser extent or not at all for priority shares, preference shares, or tracking stocks;
Cases involving government intervention, such as expropriations;
In the event of a restructuring of your BV structure, the ownership and continuation periods will be handled more flexibly.
Tax interest
There is currently a lot of discussion about the level of tax interest. This is interest that you have to pay in a number of cases when a tax assessment is imposed. The reason for this is a ruling by the District Court of Groningen on November 7, 2024, which concerned tax interest for corporate income tax. In this ruling, the court found that the tax interest stated by the tax inspector on the assessment was too high. Interest of 10% was charged on a corporate income tax assessment, which was reduced to 4% in the ruling.
This could also have an impact on the tax interest on income tax assessments. However, we must be honest and say that there are also rulings that upheld the inspector's decision to charge a higher tax interest rate.
If you receive a tax assessment for which tax interest is charged, you should contact us immediately. As long as the Supreme Court has not yet made an official ruling on the maximum permissible amount, we can file an objection against the tax interest.
Pseudo-taxation for passenger cars
An important legislative change has been announced for employers who provide their employees with a company car. This is a new measure that will take effect on January 1, 2027. This may also affect you as a DGA, because you are an employee of your own BV as an employer.
Under the new rules, employers will have to pay an additional amount of payroll tax in the form of a final levy, amounting to 12% of the catalog value of that car. This levy is calculated different when it is more than 30 years old, in this case the 12% tax is calculated on the market value instead of the catalog value. Suppose you have an employee with a company car with a catalog value of €50,000. In that case, it will cost you 12% x €50,000 = €6,000 in final levy per year. Please note that this is a tax that you must pay yourself; you may not pass it on to your employee.
The final levy is calculated per calendar month, but the employer only has to pay it in the second month after the end of the calendar year in question. This will apply for the first time in 2027, so the first payment will have to be made in February 2028.
When does this pseudo-tax apply?:
If an employer provides an employee with a company car that the employee is also allowed to use privately. Private use also includes commuting between home and work. If an employee does not use the car privately, also not commuting between home and work, the pseudo-tax does not apply. In other words, if you, as a DGA, do not use the car privately but do use it for commuting between home and work, this regulation also applies to your car;
The tax only applies to cars with CO2 emissions. The tax does not apply to completely emission-free cars. However, it does apply to hybrid cars;
The tax applies to all types of cars that are not completely emission-free, including, for example, camper vans, passenger vans for healthcare transport (with a maximum of 9 seats), and even hearses.
This tax is completely separate from the tax that the employee already pays as an additional tax liability for private use. It is an additional tax for the employer. It is therefore in addition to any additional tax liability you may already pay privately in the event of private use of the car.
A transitional arrangement applies until September 17, 2030, in the following case:
The levy only applies to cars that are made available for the first time on or after January 1, 2027.;
If an employee is provided with a car before January 1, 2027, the employer does not yet have to pay the levy.;
From September 17, 2030, the transition time ends and the levy will be mandatory for all cars. If, for example, you make a new gasoline or diesel car available to your employee on December 1, 2025, the levy have to be paid stating from September 17, 2030.
Box 3
Since 2021, there has been much discussion about box 3, the taxation of savings and investments.
The latest development is that a new law has been enacted, the Box 3 Counterevidence regulation Act. Under this scheme, you are in principle liable for box 3 tax on a notional return on your assets, insofar as this exceeds the tax-free allowance.
If you can prove that the return you actually achieved is lower than this notional return, you only have to pay tax on that lower actual return. To prove this, you must submit a digital OWR form. OWR stands for Opgaaf Werkelijk Rendement (Actual Return Statement).
If you have already paid tax on your box 3 assets for the last few years starting in 2021, you will receive a letter from the Tax and Customs Administration inviting you to submit the OWR form. This letter will also state the date by which the form must be submitted. However, this is only useful if the actual return is lower than the notional return.
When should you be particularly alert::
If you have claims on others in box 3, with a fixed interest rate, in the year 2022;
If you had homes or other immovable property in box 3, such as a second home, whose WOZ value has fallen in any year;
If you had assets with a low return, such as government bonds that pay low interest;
If you had other assets in box 3 whose value has fallen. For example, cryptocurrency in a year of declining value;
If you had other assets in box 3 whose value has fallen. For example, cryptocurrency in a year of declining value.
VAT revision for renovation services
This measure will take effect on January 1, 2026, and is only relevant if you provide VAT-exempt services, such as entrepreneurs in the medical sector, daycare centers, insurance brokerages, and other VAT-exempt entrepreneurs.
The VAT revision will now also apply to investment services relating to immovable property, with multi-year consumption and with a value exceeding the threshold amount of €30,000. The revision period will be five years (year of commissioning plus four subsequent financial years). A correction will be made both when switching from VAT-taxed to exempt use (which means repaying VAT) and vice versa (in which case you can reclaim VAT).
The effective date is January 1, 2026, and therefore only applies to investment services put into use from that date onwards. This measure does not yet apply to investment services prior to that date. If the investment was made in 2025, for example, VAT revision will not be an issue later on.
A practical example:
A healthcare institution decides to install new windows in 2026;
The costs amount to €40,000, plus €8,400 in VAT;
Let's say the pro rata is 5%, which means that the healthcare institution will be refunded 5% of that VAT (€420);
In 2027, the pro rata rate will fall to 4%, which means that the healthcare institution will have to repay part of the VAT (4/5 of €84).
Other measures
In addition to the above measures, a number of tax changes will be introduced that may be important to you as a DGA with your BV or for your private situation.
The following changes to car taxes:
The rate reduction in motor vehicle tax for zero-emission passenger cars in the period 2026–2028 will be increased from 25% to 30%;
The quarter rates in motor vehicle tax will be limited to delivery vans from July 1, 2026, and removed altogether from January 1, 2028;
The excise duty rates for unleaded petrol, diesel, and LPG will not be increased as of January 1, 2026. Fuel excise duty will remain low for another year;
The transfer tax rate for homes that are not occupied by the owner as their main residence for a long period of time (a so-called owner-occupied home in box 1) will be 8% from January 1, 2026. This includes homes purchased as investment properties or second homes. Please note that this only applies to homes and not to other immovable property;
The starter threshold for the transfer tax exemption will increase from €525,000 to €555,000;
Gambling tax will increase from 34.2% to 37.8% on January 1, 2026.
The VAT increase on culture, media, and sports as of January 1, 2026, will not go ahead; the VAT rate will remain at 9%;
The deadline for submitting inheritance tax returns is currently eight months, which will be extended to 20 months from next year. Tax interest on inheritance tax assessments will also only start to accrue after 20 months;
The VAT on accommodation (provided by hotels, B&Bs, guesthouses, and short-stay vacation companies) will increase from 9% to 21% as of 2026. However, this does not apply to camping. A transitional arrangement also applies. This concerns single-use vouchers and payments made in 2025 for services applicable to 2026 and later. In this case, too, the entrepreneur must charge 21% VAT.
The following two points are issues that have been discussed frequently and are also likely to undergo changes in the long term:
There is increasing talk of abolishing mortgage interest in the long term.
Compulsory disability insurance (AOV) for entrepreneurs has been announced. However, this only applies to entrepreneurs in the income tax sphere, such as owners of sole proprietorships. As a DGA of a BV, this does not yet apply.
To conclude, about Prinsjesdag 2025 for DGAs and their BVs
This memo outlines the most important changes announced on Prinsjesdag 2025 for DGAs. To find out exactly what consequences these new developments will have, don't hesitate to contact us, so we can optimize your tax situation.
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