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In the Budget Memorandum, the Cabinet already presents a tax account to directors-major shareholders (DGAs). DGA entrepreneurs with a debt of more than € 500,000 to their bv will probably be faced with an additional levy in box 2 of the income tax from 2020 onwards.

The Budget Memorandum (2018) states that the Cabinet will discourage the tax deferral by taxing DBAs with their own BV in excess of € 500,000 in Box 2. Many DGAs have a current account with their BV, which shows the balance of amounts that still have to be settled between the bv and the dga.

Still unclear what exactly the taxation looks like

However, this measure has not been further elaborated in the Prinsjesdag documents. Exactly how exactly the tax in Box 2 is calculated is therefore not yet clear. This information may only follow in the Tax Plan for 2020. However, in the Budget Memorandum, the government does specifically refer to current account debts and not to loans between the BV and the DGA. From this I read that loans regarding the owner-occupied home or the box3 homes will not count towards the base. Nevertheless, the government expects a revenue of € 1.8 billion next year from DGAs that will already pay a dividend to eliminate the RC.

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