# What is Box 2 (Aanmerkelijk Belang)?

Country: Netherlands

Box 2 is the Dutch income tax category for substantial interest income. It applies when a person holds at least 5% of the shares in a company. Dividends and capital gains from those shares are taxed at 24.5% on the first EUR 67,804 per person and 31% above that (2025). The threshold is per individual, not per company.

## Current rate (Calendar year; Box 2 income declared in personal income tax return)

24.5% up to EUR 67,804; 31% above (2025, per individual)

## Example

A DGA extracts EUR 100,000 in dividends from her BV. Box 2 tax: 24.5% x EUR 67,804 = EUR 16,612, plus 31% x EUR 32,196 = EUR 9,981. Total Box 2 tax: EUR 26,593. The BV already withheld 15% dividend tax (EUR 15,000), credited against this, leaving EUR 11,593 to pay.

## How Box 2 (Aanmerkelijk Belang) works in Netherlands

Box 2 is the personal income tax box covering substantial interest income (aanmerkelijk belang inkomen). It is one of three income boxes in the Dutch personal income tax system (Box 1: work and home; Box 2: substantial interest; Box 3: savings and investments).

**Who is subject to Box 2?**

Any individual holding at least 5% of:
- The shares in a company (including BV, NV, cooperative)
- Options on at least 5% of shares
- Profit certificates representing at least 5% of annual profit
- Certain hybrid instruments

The 5% test looks at each class of shares separately. Holding 5% of Class A shares and 0% of Class B shares may still trigger substantial interest on the Class A holding.

**The two-rate system (from 2024)**

From 2024, the Netherlands moved from a single Box 2 rate to a two-tier system:
- 24.5% on the first EUR 67,804 of Box 2 income per person per year
- 31% on Box 2 income above EUR 67,804

This creates a planning incentive to spread dividends over years and across partners, keeping annual distributions within the 24.5% band.

**Interaction with dividend withholding tax**

When a BV pays a dividend to a Dutch resident DGA, it withholds 15% dividend tax (dividendbelasting). This 15% is credited against the Box 2 liability on the personal tax return. The net effect:
- Dividend of EUR 100,000
- BV withholds EUR 15,000 (15% dividendbelasting)
- DGA receives EUR 85,000 net
- Box 2 tax on EUR 100,000: approximately EUR 26,593 (at combined 24.5%/31% rate)
- Less 15% credit: EUR 15,000
- Additional payment due: EUR 11,593

**Partners and the double threshold**

If both partners/spouses hold shares (or are deemed to hold shares due to the partner rule), each gets their own EUR 67,804 at 24.5%. A couple can extract up to EUR 135,608 in dividends at the lower 24.5% rate. This makes share splitting between partners a common tax planning technique.

**Capital gains also taxable**

Box 2 applies not just to dividends but also to capital gains when shares in a substantial-interest company are sold. If a DGA sells their BV for EUR 500,000 above their share acquisition cost, that gain is entirely Box 2 income.

**Emigration exit tax**

If a DGA emigrates from the Netherlands while holding a substantial interest, the Belastingdienst issues a conserverende aanslag (deferred assessment) on the accrued but unrealised gain. This exit tax prevents DGAs from emigrating and then extracting dividends tax-free. Deferral agreements exist with certain treaty countries.

Source: https://www.belastingdienst.nl/wps/wcm/connect/bldcontentnl/belastingdienst/prive/aangifte_doen/aangifte_2024/aangifte_2024_invullen/inkomen_uit_aanmerkelijk_belang/

## Related terms

- [DGA (Directeur-Grootaandeelhouder)](https://accounts-os.com/nl/glossary/dga-nl)
- [BV (Besloten Vennootschap)](https://accounts-os.com/nl/glossary/bv-nl)
- [Gebruikelijk Loon (Customary Wage)](https://accounts-os.com/nl/glossary/gebruikelijk-loon-nl)
- [Deelnemingsvrijstelling (Participation Exemption)](https://accounts-os.com/nl/glossary/deelnemingsvrijstelling-nl)