In 2026, Dutch BVs must test a working shareholder’s pay under the customary-wage rules. Salary, invoices, and payments through connected entities can form one remuneration picture. If the same work is split across payment routes, the BV may face a later payroll tax correction.
Why this matters
The BV must withhold and pay payroll tax on the customary wage. For 2026, the test uses the highest of three benchmarks. These are pay for the most comparable role, the highest employee wage in the BV or connected company, and €58,000. A lower wage needs factual support. A late correction drains cash. It can alter retained earnings, upset dividend plans, and require payroll corrections. A personal income tax return does not replace a clear payroll file.
Example
A founder receives a monthly salary from a BV and sends invoices through a sole proprietorship. Both payments cover similar customer work and decision-making. The contracts, time records, and invoices do not show a clear split. The invoice may be booked as a supplier cost. A payroll review can still see one remuneration picture. The BV may then need to correct payroll after the cash has been spent.
XTROVERSO tips
- Map every payment route. List salary, invoices, management fees, dividends, and payments through connected companies. Match each payment to specific work.
- Describe the founder’s actual role. Record duties, weekly hours, authority, customers, and management responsibility. Use the real working week, not only the company structure.
- Check all three wage benchmarks. Compare the role with similar employment, the highest-paid relevant employee, and the €58,000 reference amount for 2026.
- Test whether the work is genuinely separate. Look for separate customers, contracts, deliverables, prices, liability, and planning. Different invoices alone do not prove different work.
- Keep payroll and accounts aligned. Check that contracts, invoices, payroll records, bank payments, and tax files tell the same story. Record the reasoning before year-end.
- Model the cash impact. Estimate the payroll tax and administration cost of a correction. Add the result to cash and dividend planning.
Need your DGA pay, invoices, and payroll records checked before year-end?
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.
