Dutch tax guidance draws a sharper line between a genuine management assignment and work that functions as employment. The outcome affects which company handles payroll, how DGA salary is tested, and whether company records support the payment route.
Why this matters
A holding can genuinely serve an operating company. Trouble begins when the agreement and the working week do not match. Look at the DGA’s weekly work: who gives instructions, expects personal work, and bears the risk when a customer does not pay. An invoice alone does not answer that. Keep the management fee and DGA salary calculations separate. The fee can include costs, risk and margin. The salary file must support the DGA’s work under customary-salary rules.
Example
In a published case, a holding owned 6% of an operating company. The assignment was genuine, and the DGA worked for the holding. The through-payment rule did not apply. So the customary-salary test stayed with the holding. Results can differ if the operating company directs the DGA’s personal work. Check payroll, wage tax and employee insurance against those facts. For 2026, €58,000 is one part of the customary-salary test, not an automatic DGA salary.
XTROVERSO tips
- Map the actual working week. Record who directs the work, approves decisions and carries customer or supplier risk. Start with current practice, not the old contract.
- Check the contract against the facts. Compare the management agreement with the DGA’s authority, duties, hours and place among staff. Record any change in the role.
- Separate the fee from the salary. Document the services, costs, risk and margin in the management fee. Keep a separate file for the DGA salary.
- Test the 2026 salary calculation. Review comparable employment, the highest-paid employee and the €58,000 statutory amount. Keep the evidence behind the outcome.
- Make the records agree. Check the contract, board minutes, invoices, payroll, annual accounts and tax returns. Each document should describe the same arrangement.
- Review payroll and insurance separately. Check whether the through-payment rule could apply. Ask an adviser to assess employee-insurance status from the actual facts.
Want a second look at your contract, payroll route and DGA salary file? Our team can identify where the records diverge
The data, sourcing, and analysis behind this article were conducted by Linda Pavan. AI was not used to identify sources, build the factual basis, or produce the analytical judgment contained here. AI was used only as a drafting aid. The final English text was personally reviewed, edited, and approved by Linda Pavan before publication.
References
- Belastingdienst Kennisgroepen – Doorbetaaldloonregeling bij reële overeenkomst van opdracht
- Belastingdienst Kennisgroepen – Voorwaarden doorbetaaldloonregeling in aanmerkelijkbelangverhoudingen
- Belastingdienst – Loon en aanmerkelijk belang
- Belastingdienst – Wanneer is sprake van loondienst?
- Belastingdienst – Gevolgen voor de opdrachtgever bij loondienst
- UWV – Verzekeringsplicht
- Belastingdienst – Handboek Loonheffingen 2026
