Dutch BVs will still face the earnings stripping rule in 2026. The deduction cap remains linked to corrected profit and a fixed threshold. Ordinary borrowing can still tighten Vpb cash.
Why this matters
A BV can pay bank interest now and still lose deduction room this year. The blocked amount rolls forward. It does not cover payroll, supplier invoices, rent, instalments, or the current Vpb bill. The strain shows in the tax file, not the bank screen.
Example
A wholesale BV borrows for stock and extra warehouse space. Sales stay flat, but margin slips. The loan file sits beside the Vpb return. The owner checks whether corrected profit still leaves room.
XTROVERSO tips
- Map every financing item. List bank loans, shareholder loans, leases, factoring, current-account balances, property debt, finance fees, and interest income. Keep the list with the Vpb file, not only in the bank folder.
- Test a lower-profit year. Run one low-profit case with thinner margin, slower customers, or a lost tenant. See whether corrected profit still leaves enough interest deduction room.
- Track carried-forward interest. Disallowed interest can move into later years. Record it by year and link it to the assessment. Do not treat it as cash relief for this year.
- Check real estate entities early. Some real estate bodies that rent to third parties lost the €1,000,000 deduction space from 2025. That can change the cash forecast quickly.
- Classify fees before year-end. Factoring, lease components, finance fees, and interest-like amounts need tax review. A ledger label does not always decide article 15b treatment.
Need a one-page BV financing check before the next tax close?
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
- Earningsstrippingregeling onder vuur, ATAD wordt versoepeld - Taxence
- Wettenbank - Current statutory rule under article 15b Wet Vpb
- Belastingdienst - Belastingdienst 2026 taxpayer-facing Vpb update
- Belastingdienst - Belastingdienst direct page on the generic interest deduction limitation
- Rijksoverheid - Belastingplan 2025 policy frame and real estate anti-fragmentation
- Rijksoverheid - Official 2025 public tax changes summary
- Wettenbank - Besluit Earningsstrippingmaatregel 2025
- Rechtspraak - Court signal on factoring and article 15b
