A tax position published on 15 July 2026 confirms that a management fee alone cannot support the doorbetaaldloonregeling. The payroll route depends on whether the DGA also works for the work BV as an employee. That determines where payroll and the usual-wage assessment belong.
Why this matters
A work BV can buy management services from a holding without employing the DGA. Payroll and the usual-wage file then remain with the holding. For 2026, the statutory reference amount is €58,000. It is one part of the test. A low or unpaid cash salary can still lead to a fictitious-salary adjustment and wage tax in the holding.
Example
In the published case, the DGA was employed by his holding. The holding owned 6% of a work BV and invoiced €120,000 a year. €20,000 covered costs, charges and depreciation. There was a genuine services agreement, but no employment relationship with the work BV. There was no shared entrepreneurship. The doorbetaaldloonregeling did not apply. The usual-wage assessment stayed with the holding.
XTROVERSO tips
- Map the DGA’s work. List each company where the DGA works. Record who gives authority, signs contracts, carries risk and receives the service.
- Check the employment link. Do not treat a management invoice as proof of employment. Confirm whether the DGA has an employment relationship with the work BV.
- Read the records together. Compare the management agreement with invoices, board decisions, payroll entries and payment flows. They should describe the same arrangement.
- Keep the wage file in the right BV. Keep the usual-wage assessment with the BV that employs the DGA. Support it with the role, hours, comparable work and employee wage data.
- Plan the holding’s cash. Reconcile management-fee income with salary, wage tax, costs, dividends and shareholder current-account movements. An invoice is not free cash.
Need a clear check of your contracts, payroll records and DGA wage position? We can review how they fit together
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 AB-verhoudingen
- Belastingdienst — Handboek Loonheffingen
- Belastingdienst — Niet elke opdracht kan buiten loondienst
- Taxence — Standpunt doorbetaaldloonregeling bij reële overeenkomst van opdracht
