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Directors loans to be taxed differently

This information is provided by:Netherlands Enterprise Agency, RVONetherlands Enterprise Agency, RVONederlandse versieEffective date: 1 January 2023

What changes?

Do you borrow money from your own private limited company (bv)? The government wants to limit the possibilities for DGA's (director-major shareholders) to do so through so-called the current account (rekening courant, RC) measure and to prevent tax deferral in Box 2 through director loans. With this measure debts of over €700,000 will be taxed in Box 2 of the income tax rates. You pay 26.9% income tax over this in box 2.

The €700,000 limit also applies if you use surplus liquid assets in your holding for private investments.

For whom?

  • owners (DGA's) who borrow money from their own private limited company (bv)


The law against taking out excessive loans from one's own company is expected to come into force on 1 January 2023. Those who own more than 5% of shares in a company (aanmerkelijkbelanghouders) have until 31 December 2023 to prepare themselves.

Please note: The effective date of this measure is not yet final. Entry into force is subject to its passing through the upper and lower houses of parliament or proclamation of the Order in Council (Algemene Maatregel van Bestuur, AMvB) or ministerial decree and publication in the Staatsblad or Staatscourant(Government Gazette, in Dutch).

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