Dutch tax proceedings question whether consultancy receipts belong to a CV, a BV or the person behind them. The answer affects who reports the income and what cash remains for tax, payroll and private use.
Why this matters
Before cash planning begins, the file must identify the receipt’s tax owner. The contract, invoice, bank receipt, VAT return and ledger should name the same party. If a BV earned the income, cash paid to its founder needs a recorded route. That may be salary, dividend, a loan, repayment or a current-account entry. Corporate income tax is 19% on taxable profit up to €200,000 in 2026. Above that, the rate is 25.8%. Corporate-tax interest is 5%.
Example
An IT consultant contracts through a BV. The BV sends a €40,000 invoice, reports VAT and receives payment. Later, the consultant transfers €10,000 to a private account. The bank transfer alone does not explain it. The company file should show salary, dividend, a loan, repayment or a current-account withdrawal. Without that record, a correction may affect corporate income tax, wage tax, dividend tax, VAT and tax interest.
XTROVERSO tips
- Trace one large invoice. Check the contract, invoice, bank receipt, VAT return and ledger entry. The same entity should appear throughout the file.
- Record private transfers. Label money moving from the company to the founder. Keep the decision, agreement or payroll record that supports the chosen route.
- Review the provisional assessment. Compare expected 2026 taxable profit with the provisional corporate-tax assessment. Request a change when the estimate no longer fits.
- Separate old CV years. For a former open CV, make a timeline for the receipt year, the 2024 closing position and the change from 1 January 2025.
- Allow for tax interest. Leave room in the cash plan while an attribution question or correction remains open. Corporate-tax interest is 5% in 2026.
Need a clear route from invoice to company cash and private use? We can help prepare records and questions for your adviser
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
- Rechtspraak — Consultancy receipts, CV, BV and alleged double attribution (ECLI:NL:PHR:2026:283)
- Rechtspraak — Corporate return duty and the person behind the company (ECLI:NL:HR:2026:424)
- Belastingdienst Kennisgroepen — Open-CV corporate-tax status after 2025
- Belastingdienst Kennisgroepen — Transition detail for former open-CV structures
- Belastingdienst — Corporate income tax rates for 2026
- Belastingdienst — Corporate-tax interest percentages
- Belastingdienst — Provisional corporate-tax assessments
