In 2025, dividend tax undergoes significant changes that affect both private investors and director-major shareholders (DGA). These adjustments open opportunities for tax planning but also require careful consideration of how various tax rules interact. Here’s an overview of the most important changes and their implications.

New Rate Structure in Box 2

The Box 2 rate structure will be revised in 2025. For dividends up to €67,804, the rate remains unchanged at 24.5%. For distributions above this threshold, the rate decreases from 33% to 31%. This reduction makes larger dividend distributions in 2025 more appealing, particularly for DGAs who may have previously been deterred by the higher rate.

Fiscally partnered individuals will also see a similar adjustment. In 2025, the lower rate applies to combined distributions up to €135,608, after which the higher rate of 31% takes effect. This change provides more flexibility for partners to optimize dividend payouts at a reduced tax rate.

Effective Tax Burden Due to General Tax Credit Adjustments

While the nominal rate for the first Box 2 bracket remains at 24.5%, the effective tax burden on dividend distributions in 2025 could increase. This is due to changes in the general tax credit, which will be reduced based on total combined income (Box 1, 2, and 3) starting in 2025. Larger dividend payouts may reduce the tax credit, indirectly increasing the overall tax burden.

Dividend Tax as a Withholding Tax

The 15% dividend tax remains in place as a withholding tax in 2025. This amount can still be offset against the final income tax payable under Box 2. For investors and DGAs, this means the immediate tax impact does not change, but the final liability will still depend on total income and the applicable Box 2 rates.

Planning Considerations for DGAs and Investors

The 2025 changes present new opportunities for strategic tax planning. DGAs may consider distributing dividends in 2024 up to the €67,000 threshold (€134,000 for fiscal partners) to benefit from the lower 24.5% rate. For larger payouts, it could be more advantageous to wait until 2025, when the top Box 2 rate drops to 31%. This approach can result in significant tax savings but requires careful evaluation of income and tax impacts.

Strategic Tax Planning for 2025

The changes to dividend tax in 2025 offer opportunities for tax optimization but also add complexity. The interaction between the new rates, the reduction of the general tax credit, and fiscal rules for partners makes a well-thought-out strategy essential.