For 2026, Dutch DGA payroll checks focus first on whether the person works for a BV or cooperative in which they hold a substantial interest. The salary position matters because low pay must be supported by ownership facts, actual work, market comparison, group wages, and payroll processing.
Why this matters
A low DGA salary is not mainly a cash-flow question. The customary-wage rule applies when someone works for a company or cooperative in which that person, possibly together with a fiscal partner, has a substantial interest. In practice, the 5% line often starts the discussion, and shares, options, profit rights, liquidation rights, and voting rights can all be relevant. Once the rule applies, the 2026 wage must normally be at least the highest of three amounts: the wage from the most comparable employment, the wage of the highest-paid employee at the company or a connected company, and €58,000. Cash pressure can matter, but it does not replace the wage comparison. A lower salary needs a file that explains the work, the market value of that work, the group situation, and the payroll treatment.
Example
A founder owns more than 5% of a BV and works in the business. The BV has uneven sales and wants to keep cash available for suppliers, stock, software, and staff. That cash concern is understandable, but it is not enough by itself. The first question is whether the founder falls under the customary-wage rule. If yes, the BV must compare the role with a real market wage and check whether anyone in the company or a connected company earns more. If the founder works limited hours in a simple role, a lower market wage may be defensible. If the founder is effectively running the business full time, managing staff, finance, commercial risk, and daily decisions, the file must support why the wage is lower than the normal benchmark.
XTROVERSO tips
- Start with ownership and work Check whether the person has a substantial interest and actually works for the BV or cooperative. A job title alone is not enough. A hired CEO without a substantial interest is different from a founder-director-shareholder who works in the business.
- Do not treat €58,000 as the only number For 2026, €58,000 is only one of the three benchmarks. The wage of the most comparable employment and the wage of the highest-paid employee in the company or a connected company can lead to a higher amount.
- Build evidence before payroll closes Document the role, hours, responsibilities, sector, complexity, comparable wages, and group wages. Old benchmark notes can become weak when wages in the market move.
- Keep cash arguments specific Cash pressure may support a lower wage only when the story is concrete. Show why paying the higher wage would affect continuity, liquidity, stock, or assets needed for the business. A general loss or a preference to keep money in the BV is not enough.
- Make the payroll administration match the position If the DGA receives less than the customary wage, the difference may have to be processed as fictitious wage for payroll tax purposes. Also check current-account debt, dividends, management fees, and other withdrawals. A low salary position becomes fragile when value leaves the BV in another way.
- Ask early if the position is material For a significant or sensitive lower-wage position, advance consultation can help. The request should explain the work, comparable wages, the highest employee wage, connected companies, and the reason for no wage or lower wage.
Want to check whether your DGA salary position is defensible before payroll closes?
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 - Applicability gate: DGA or substantial-interest holder
- Belastingdienst - 2026 customary-wage benchmark
- Belastingdienst Kennisgroepen - Connected companies and highest-paid employee
- Belastingdienst - Payroll filing cadence
- Rechtspraak - Court signal: narrow financial-distress acceptance
- Rechtspraak - Supreme Court purpose and comparison method
- Belastingdienst Kennisgroepen - Pre-incorporation BV period
- Belastingdienst - Vooroverleg and evidence checklist
