A director-shareholder (DGA) of a Dutch BV with a 5% or greater holding must draw a "customary salary" (gebruikelijk loon) of at least €58,000 in 2026 (up from €56,000 in 2025). The full rule is a three-test waterfall: comparable employment, the highest-paid employee in the group, or the statutory floor, whichever is highest. Exemptions exist for genuinely passive setups, and the position can differ if you're not a Dutch tax resident.
This guide is general information, not tax or legal advice. Rules and rates change; check the current position and get advice on your own situation before acting.
What is a DGA?
DGA stands for directeur-grootaandeelhouder: a director who is also a "major" shareholder, holding at least 5% of the shares directly or indirectly (for example, through a personal Holding BV). It's by far the most common configuration for a founder of a Dutch BV: you're both the person running the company and the person who owns it.
Because the DGA is simultaneously an employee (the director) and an owner (the shareholder), Dutch tax law has to decide how much of the money you extract is salary (taxed as employment income) and how much is a return on your shares (taxed as investment income). The customary-salary rule is how it draws that line.
The customary-salary rule (gebruikelijk loon)
The gebruikelijk loon rule sets a minimum salary the BV must pay its DGA. That minimum is the highest of three tests, applied as a waterfall:
- Comparable employment. What a non-shareholder employee would be paid for the same work in a comparable role. If a hired managing director would command €90,000, that's the benchmark.
- Highest-paid regular employee. The salary of the most highly paid ordinary employee in the BV or the affiliated group. If your best-paid developer earns €75,000, the DGA salary can't reasonably sit below that.
- Statutory floor. A fixed annual minimum, set at €58,000 in 2026 (it was €56,000 in 2025).
You take whichever of the three is highest. In practice, for most early-stage founders with no senior hires and no clearly higher "comparable" wage, it's test 3, the statutory floor, that applies. As a working rule of thumb: a single-founder BV should budget for a €58,000 gross DGA salary in 2026 unless it can substantiate a lower figure.
| Customary-wage test | What it measures |
|---|---|
| 1. Comparable employment | Market pay for the same role, non-shareholder |
| 2. Highest-paid employee | Top regular salary in the BV or group |
| 3. Statutory floor | €58,000 (2026) |
Why the rule exists
Without it, a founder could pay themselves no salary at all and extract everything as dividends. Dividends are taxed in Box 2 (substantial-interest income) at roughly 24.5% up to about €68,000 and 31% above that in 2026, while a salary is taxed in Box 1 at progressive personal rates plus social contributions. Skipping salary entirely would avoid the wage-tax and social-charge layer that ordinary employees pay.
The customary-salary rule closes that gap. It forces a minimum amount to be treated as Box 1 employment income, so the DGA contributes wage tax (and, where applicable, social charges) like any other senior employee. Anything above the customary salary can still be taken as dividend.
When you can draw a lower salary
The €58,000 floor is a default, not an absolute. There are three routes to a lower number, in ascending order of how often they actually apply:
- The customary-wage exemption. If the customary wage for the work would be €5,000 or less in a year, no salary need be set. This rarely helps an active founder; it's aimed at genuinely marginal activity.
- A formal request for a lower customary wage (verzoek lager gebruikelijk loon). You can ask the Belastingdienst to apply test 1 or test 2 below €58,000 where you can substantiate that comparable employment or the highest-paid employee genuinely sits lower. This needs evidence, not just an assertion.
- A genuinely passive holding. Where no labour is performed at all (for example, a pure asset-holding BV with no operating activity), a documented case for a €0 customary wage can stand. The key word is documented: the Belastingdienst will test whether work is really being done.
Working out which route fits your setup is worth doing with an accountant or tax adviser, since it depends on your specific circumstances.
DGA salary when you hold through a Holding
Some founders hold their Dutch BV through a separate Holding company rather than personally. The customary-wage rule doesn't change in substance, but where it's paid can:
- The rule applies once across the whole group, not per BV. You don't owe €58,000 at the Holding and €58,000 at the Operating BV.
- In that setup, the Holding typically pays the DGA salary, funded by a management fee from the Operating BV.
That's general information about how the mechanics work, not something we arrange for you. If you already hold your BV through a separate Holding, or you're weighing up whether to, the holding-structure guide covers the trade-offs.
Box 1 vs Box 2: the numbers
The whole point of getting the DGA salary right is to land on an efficient split between salary and dividend. The two boxes work very differently:
| Box | What it taxes | 2026 rate |
|---|---|---|
| Box 1 (salary) | Employment income, progressive | ~35.75% to 49.5% |
| Box 2 (up to ~€68k) | Dividends, lower band | ~24.5% |
| Box 2 (above ~€68k) | Dividends, upper band | ~31% |
On top of Box 1, a health-insurance contribution (ZVW) applies up to a ceiling. Verify the exact 2026 brackets at filing time; the Tax Plan figures are indexed and can be amended late in the year.
For a typical founder without the 30% ruling, a common mix is: take the €58,000 customary salary in Box 1, and take any further cash as a Box 2 dividend. The salary is also deductible against the BV's profit, so it reduces corporate tax (Vpb) at the same time. For the full corporate-side picture, see the Dutch BV tax 2026 guide.
Interaction with the 30% ruling
If you qualify for the 30% ruling, roughly 30% of your taxable salary becomes tax-free, capped at the Balkenende norm. Against a €58,000 DGA salary, that means an effective taxable portion of about €40,600, with roughly €17,400 received free of tax.
This is why founders who qualify sometimes top up their DGA salary deliberately: a higher salary means a larger tax-free 30% slice (up to the cap). Note that the ruling reduces to 27% from 1 January 2027, and it applies to employees relocated to the Netherlands, not automatically to a non-resident founder who never moves.
The non-resident DGA
If the DGA is not resident in the Netherlands and performs their work abroad, the relevant tax treaty usually allocates the taxation of that labour income to the country of residence. In that situation, Dutch wage tax may not actually be due on the DGA salary. But this is a documentation-heavy position, not a free pass:
- A payroll record is still required, even if no Dutch wage tax is ultimately paid. The administration has to exist.
- The Belastingdienst scrutinises cross-border DGA setups, especially where questions arise about whether the BV is effectively managed in the Netherlands while the DGA works from abroad.
- A wage-tax exemption needs careful evidence: a treaty residency certificate, records of your working pattern, and a coherent position on where the company is actually managed. See our note on tax residence for the wider point this connects to.
This is exactly the kind of position where getting your own tax advice early, and getting the paperwork right from the start, is far cheaper than reconstructing it under audit.
Year-end check
The customary salary is assessed on the calendar year, so December is the moment to check what you've actually drawn. If your year-to-date salary is below €58,000 (or below whatever threshold applies to you), the usual fix is a year-end bonus run through payroll to top up to the floor before 31 December.
It's much easier to top up in advance than to argue a shortfall with the Belastingdienst after the fact. A short December review, alongside your VAT and accounts deadlines, keeps the position tidy.
Penalties for non-compliance
If you under-pay the customary salary, the Belastingdienst can reclassify the difference as deemed salary: it treats dividends or undeclared amounts as wages that should have been paid. That brings back wage tax, social charges, penalties and interest, applied retroactively. In cases of material, deliberate non-compliance it can, in principle, lead to further investigation, though that's uncommon.
The practical takeaway is simple: the customary-salary rule is one of the more routinely checked items for owner-managed BVs, so it's not a corner worth cutting. Running a proper payroll from the start removes the risk.
FAQ
Document the absence and apply for a verzoek lager gebruikelijk loon (request for a lower customary wage) with substantiation. The Belastingdienst usually accepts a genuinely low-activity year if you can evidence it.
No. An active DGA must draw at least the customary salary; only a genuinely passive holding company with no labour performed can argue for €0.
The salary obligation still exists, and wages payable to you still accrue in the BV's books even if you defer the actual cash payment while cash is tight. Talk to your accountant about how to record it.
Gross. What lands in your pocket net depends on your personal tax situation, the 30% ruling if it applies to you, and any social-security position.
Through a standard monthly payroll administration that files wage tax and any social contributions. Most founders set this up with an accountant or payroll provider.
The rule is about your Dutch BV's payroll obligation, not your residence, so it can still apply in principle. But if you're not a Dutch tax resident and perform your work abroad, the relevant tax treaty may allocate the taxation of that salary to your country of residence, so Dutch wage tax may not actually be due, even though a payroll record is still required. Get advice on your own situation.