A director-shareholder (DGA) of a Dutch BV with a ≥5% 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, highest-paid employee in the group, or the statutory floor, whichever is highest. Exemptions exist for genuinely passive setups.
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 is by far the most common configuration for a founder of a Dutch BV, you are 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), the tax system 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 is 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 cannot 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 an arguable "comparable" wage, it is test 3, the statutory floor, that bites first. So 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 €67,000 and 31% above that in 2026, while a salary is taxed in Box 1 at progressive personal rates plus social contributions. By skipping salary entirely, a founder 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, which is where the planning happens.
When you can draw a lower salary
The €58,000 floor is a default, not an absolute. There are three legitimate 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 is 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 requires 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.
Not sure which route fits your setup? Our team handles the customary-wage position alongside your payroll. See the accounting service →
DGA salary in a Holding+OpCo structure
If you run the standard founder structure, a personal Holding BV that owns an Operating BV, the customary-wage rule changes shape in a useful way:
- The rule applies once across the whole group, not per BV. You do not owe €58,000 at the Holding and €58,000 at the OpCo.
- In the standard setup, the Holding pays the DGA salary, and the Operating BV pays a management fee to the Holding to fund it.
- This keeps the salary obligation at the Holding only and leaves the Operating BV clean, which matters for valuation, for taking on co-founders or investors at the OpCo level, and for a future sale of the operating business.
This is one of the main reasons founders set up a Holding-on-top from day one. If you have not yet chosen a structure, the holding-structure guide walks through the management-fee mechanics, or see the Holding + Operating BV package at €2,495 all-in.
Box 1 vs Box 2: the math
The whole point of getting the DGA salary right is to land on the most tax-efficient split between salary and dividend. The two boxes work very differently:
| Box | What it taxes | 2026 rate |
|---|---|---|
| Box 1 (salary) | Employment income, progressive | ~36.97% to ~49.5% |
| Box 2 (≤ ~€67k) | Dividends, lower band | ~24.5% |
| Box 2 (above ~€67k) | Dividends, upper band | ~31% |
On top of Box 1, a health-insurance contribution (ZVW) of around 5.32% applies up to a ceiling. Verify the exact 2026 brackets at filing time, the Tax Plan figures are indexed and were amended late.
For a typical founder without the 30% ruling, the efficient mix is: take the €58,000 customary salary in Box 1 (which, including social charges, costs roughly €20,000 to €25,000 in tax), 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 often deliberately top up their DGA salary: a higher salary means a larger tax-free 30% slice (up to the cap), so the ruling rewards taking more income as salary rather than dividend, the opposite of the default advice. Note 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 foreign-resident DGA, the special case
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 increasingly scrutinises cross-border DGA setups, especially where the BV is argued to be "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.
This is precisely the kind of setup where getting the paperwork right at the start is far cheaper than reconstructing it under audit. Talk to us about your residency position →
Year-end check
The customary salary is assessed on the calendar year, so December is the moment to check what you have actually drawn. If your year-to-date salary is below €58,000 (or below whatever threshold applies to you), the clean fix is a year-end bonus run through payroll to top up to the floor before 31 December.
It is much easier to top up in advance than to argue a shortfall with the Belastingdienst after the fact. Building a short December review into your routine, 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 extreme cases of material, deliberate non-compliance it can trigger a criminal investigation, though that is rare.
The practical takeaway is simple: the customary-salary rule is one of the most routinely checked items for owner-managed BVs, so it is not a corner worth cutting. Running a proper payroll from the start removes the risk entirely.
FAQ
Document the absence. 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.
Not since the gebruikelijk loon rule was tightened. The old salary-zero, dividend-only plays are squarely caught. An active DGA must draw at least the customary salary; only a genuinely passive holding with no labour performed can argue for €0.
The salary obligation still exists, and you accrue wages payable to yourself. In practice many founders defer the cash payment when cash is tight, but the accounting and tax liability still accrue on the books.
Gross. The €58,000 is the gross customary salary. What lands in your pocket net depends on your personal tax situation, the 30% ruling, and any social-security position.
Through a standard monthly payroll administration that files wage tax and any social contributions. Our DGA payroll service costs €45/month plus a €120 one-off setup and handles the filings for you.
The €58,000 floor is indexed annually, so the 2027 figure is not yet known. Separately, the 30% ruling reduces to 27% from 1 January 2027, which affects qualifying founders rather than the customary-wage floor itself.
Want the salary handled without thinking about it? Our DGA payroll runs at €45/month plus a €120 setup. See the accounting service →