In 2026, administrative work by a substantial-interest holder can bring the Dutch customary-salary rule into play. Contracts, management invoices, payroll and actual duties must describe the same working relationship. Gaps can create wage-tax and cash pressure at year-end.
Why this matters
A low or nil DGA salary must match the founder’s real work. Approving payments, checking payroll, signing tax papers or making final decisions can show continuing work. For 2026, the salary is generally the highest of comparable pay, the highest-paid employee’s pay or €58,000. A lower amount needs factual support. Deemed salary may require payroll treatment on 31 December. Late corrections can affect wage tax and cash set aside for suppliers or debt.
Example
After stepping back, a founder works four hours a week. A spouse handles customers and staff. The founder answers tax letters, approves bank payments and speaks with the accountant. Those hours carry the company’s final financial authority. Yet payroll records no DGA salary. The holding contract names the holding, but emails and decisions point to the operating company. Management invoices, intercompany records and payroll should follow the actual work.
XTROVERSO tips
- Map the founder’s work. List tasks performed since 1 January. Include tax letters, bank payments, payroll checks, signatures, customer decisions and contact with advisers.
- Identify the receiving company. Link each recurring duty to the holding, operating company or cooperative that directs the work and benefits from it.
- Check the salary benchmarks. Compare the DGA salary with comparable employment, the highest-paid employee and the 2026 amount of €58,000.
- Support any lower salary. Keep a dated file covering duties, hours, authority, market pay and why the lower amount fits the role.
- Reconcile records before year-end. Check the contract, management invoices, intercompany entries, payroll ledger and expected 31 December treatment. Resolve gaps while cash remains available.
Need clarity on the DGA role before payroll closes? We can review the company file and payroll position with you
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
- Door verrichtte administratieve werkzaamheden sprake van gebruikelijk loon · Salaris Vanmorgen
- Belastingdienst - 2026 customary-salary rule for substantial-interest holders
- Belastingdienst Kennisgroepen - Highest-paid employee as a separate salary benchmark
- Belastingdienst Kennisgroepen - Holding and operating-company work after the July 2026 Kennisgroep update
- Belastingdienst Kennisgroepen - Real assignment agreement versus work performed for the holding
- Belastingdienst - Timing of deemed salary and year-end payroll exposure
- Rechtspraak - ECLI:NL:GHARL:2026:4305
