What salary must a DGA pay themselves in the Netherlands?
A directeur-grootaandeelhouder (DGA) in the Netherlands must pay themselves a minimum salary of EUR 56,000 gross per year in 2025, or the market rate for their role if higher. This is the gebruikelijk loon (customary wage) rule enforced by the Belastingdienst to prevent DGAs from avoiding personal income tax by taking only dividends.
Detailed Explanation
## DGA Gebruikelijk Loon — The Mandatory Minimum Salary Rule
When you are both the director and majority shareholder of a Dutch BV, you are a DGA (directeur-grootaandeelhouder). The Belastingdienst applies the gebruikelijk loon rules to ensure you take a realistic salary from your BV rather than avoiding Box 1 income tax by paying yourself only low-taxed Box 2 dividends.
### The Minimum Salary in 2025
The gebruikelijk loon is the highest of: 1. EUR 56,000 gross per year (the absolute minimum set by legislation for 2025) 2. 75% of the salary of the most comparable employee in your own company or BV group 3. The highest salary paid to any employee in the same company or group
For most small BVs with no other staff or only junior staff, the EUR 56,000 minimum applies.
### Why the Gebruikelijk Loon Exists
Without this rule, a DGA could: - Pay themselves EUR 0 salary (no Box 1 income tax) - Leave all profit in the BV (tax at 19%/25.8% VPB) - Periodically declare dividends (Box 2 at 24.5%/33%)
The combined VPB + Box 2 rate (approximately 39 to 48%) is substantially lower than Box 1 rates (up to 49.5% plus social contributions). The gebruikelijk loon forces a portion of income through Box 1 to ensure adequate social contributions and income tax are paid.
### How Salary vs Dividend Works in Practice
For most DGAs, the optimal structure involves:
Monthly salary
Process EUR 56,000 / 12 = EUR 4,667 gross per month through payroll. The BV withholds loonheffingen and remits to the Belastingdienst monthly.
Dividend
After the BV has paid VPB on profits, the residual profit can be distributed as dividend. The BV withholds 15% dividendbelasting (dividend withholding tax). The DGA declares the gross dividend in Box 2 of their personal income tax return and credits the 15% already withheld.
Note: DGAs on a BV payroll are not eligible for WW (unemployment benefit) or WIA (disability income). The DGA does accumulate AOW (state pension) entitlement through national insurance premiums on their salary.
### The EUR 56,000 Threshold for Lower-Profit BVs
If your BV's profit before salary is below EUR 56,000, you have a practical problem. Options: - Apply to the Belastingdienst for a lower gebruikelijk loon based on company financial circumstances - Demonstrate via a comparable salary benchmark that the market rate for your role is lower
The Belastingdienst can accept a lower salary for starter BVs or loss-making companies, but you need to apply and receive approval, not simply pay yourself less.
### Dividend Optimisation Within the Rules
Once EUR 56,000 salary is paid and VPB is computed on the remaining profit, dividend distributions are taxed in Box 2: - First EUR 67,804: 24.5% - Above EUR 67,804: 33%
Optimal dividend timing includes: declaring dividends when Box 2 income is below EUR 67,804 to benefit from the lower 24.5% rate; and managing the Wet Excessief Lenen rules (any DGA loan from the BV exceeding EUR 700,000 is a deemed dividend).
### Loonheffingen on the DGA Salary
The DGA salary is processed via the standard payroll declaration (aangifte loonheffingen) filed monthly. The loonheffingen includes: - Loonbelasting/premie AOW, ANW, WLZ (the Box 1 income tax advance) - ZVW income-dependent health insurance contribution (paid by employer)
WW and WIA premiums are generally not paid by the DGA's BV because the DGA does not qualify for these benefits.
Source: https://www.belastingdienst.nl/wps/wcm/connect/bldcontentnl/belastingdienst/zakelijk/personeel_en_loon/dga/gebruikelijk_loon/
Real-World Examples
Standard DGA in a profitable BV
A BV earns EUR 200,000 profit before DGA salary. The DGA pays EUR 56,000 salary, reducing VPB-liable profit to EUR 144,000. VPB: EUR 144,000 x 19% = EUR 27,360. After VPB, EUR 116,640 is available for dividend at 24.5% Box 2. Total tax: salary Box 1 tax on EUR 56,000 + EUR 27,360 VPB + Box 2 on dividend.
Low-profit startup BV
A new BV earns EUR 40,000 in its first year. Paying EUR 56,000 mandatory salary would create an immediate loss. The DGA applies to the Belastingdienst to reduce the gebruikelijk loon to EUR 40,000 for this year, supported by management accounts showing the BV cannot pay more.
DGA near the Wet Excessief Lenen threshold
A DGA has borrowed EUR 650,000 from their BV over the years. The BV earns a further EUR 100,000 dividend and the DGA's loan balance will reach EUR 750,000. The excess EUR 50,000 above EUR 700,000 is a deemed Box 2 dividend under Wet Excessief Lenen and must be declared in the personal income tax return.
Common Mistakes to Avoid
- Paying a salary below EUR 56,000 without formal Belastingdienst approval — the Belastingdienst will impute the difference as additional salary and charge back-taxes and interest
- Forgetting to process the DGA salary through a formal payroll declaration — the BV must register as an employer and file monthly loonheffingen even for a single DGA
- Assuming the DGA salary is freely adjustable mid-year — it should be set at the start of the year and processed consistently monthly
- Not accounting for the Wet Excessief Lenen rules when borrowing from the BV — cumulative loans above EUR 700,000 trigger deemed dividend taxation
Frequently Asked Questions
Can the DGA salary be paid as a year-end lump sum?
Technically the salary should be paid monthly consistent with normal employment practice. A year-end lump sum is a red flag for the Belastingdienst. In practice, many small BVs process monthly but the actual bank transfer to the DGA varies — discuss with your accountant what is permissible in your situation.
What if the DGA works part-time?
The EUR 56,000 minimum applies to a full-time DGA. For a part-time DGA, the gebruikelijk loon can be pro-rated to the hours worked. The Belastingdienst expects the pro-rated salary to reflect the actual time commitment to the BV.
Does the EUR 56,000 include holiday allowance (vakantiegeld)?
The EUR 56,000 is the total gross salary figure. Holiday allowance (typically 8% of annual salary) is usually included within this amount or on top, depending on how the employment contract is structured. Check with your payroll adviser — the total cost to the BV should be at least EUR 56,000.
Is the DGA salary deductible for VPB?
Yes. The DGA salary and associated employer costs (employer ZVW contribution) are fully deductible from the BV's commercial and fiscal profit, reducing the VPB base. This is why the salary reduces VPB-liable profit in the standard calculation.
What happens at the end of the year if the DGA salary should be higher?
If at year-end the Belastingdienst determines the gebruikelijk loon should have been higher, they will issue an additional loonheffingen assessment to the BV for the underpaid tax on the salary shortfall. This also affects the VPB return as the imputed additional salary is deductible.
Practical Tips
- Set your DGA salary at EUR 56,000 from day one unless your accountant has confirmed a lower amount is approved — do not wait for the Belastingdienst to challenge
- Register the BV as an employer with the Belastingdienst immediately on incorporation to receive a loonheffingennummer for monthly payroll declarations
- Review the gebruikelijk loon each year in January — the statutory minimum increases annually and you must update payroll if the new minimum exceeds your current salary
- Document any application for a lower gebruikelijk loon in writing and keep the Belastingdienst response on file — in an audit you need to demonstrate formal approval
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