DGA loans from a BV now face box 2 risk through two routes: disguised distribution and borrowing above the legal limit. The ledger, bank transfers, and tax file all matter.
Why this matters
The BV and the private account can look like one cash pool. Tax law does not. A missed repayment, unpaid interest, or a home-loan entry can move the tax file. The ledger, bank file, and tax return must still match.
Example
A founder pays private bills through the BV current account. Interest is booked but never paid. Repayment dates pass, and the accountant leaves the record unchanged. The receivable still sits in the balance sheet, but the BV no longer acts like a creditor. Box 2 risk rises.
XTROVERSO tips
- Keep the current account small and short. Use the current account for small, short transfers only. Belastingdienst treats €17,500 as the practical line. Above that balance, interest is charged on the full year amount.
- Put structural borrowing in a loan file. Keep a signed loan agreement, repayment dates, businesslike interest, and security where needed. File it with bank statements, the ledger, and the returns.
- Track the €500,000 limit. Add all debts to the own BV when you check the €500,000 threshold. Above that level, box 2 tax can arise even if the civil-law debt remains.
- Act when dates are missed. Send reminders when dates are missed. Record board decisions, change terms only for business reasons, and keep proof of collection steps in the file.
- Separate home debt from other private debt. Own-home borrowing needs separate tracking. Keep the mortgage right, the loan purpose, sale proceeds, and remaining balance clear in the file.
Want a quick check of your DGA loan file 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.
References
- Geen winstuitdeling zonder prijsgeven vordering bv - Taxence
- Wettenbank - Wet inkomstenbelasting 2001, article 4.12
- Wettenbank - Wet excessief lenen bij eigen vennootschap
- Belastingdienst - Income from substantial interest
- Belastingdienst - Aanmerkelijk belang and excessive borrowing
- Wettenbank - Verzamelbesluit aanmerkelijk belang 2025
- Belastingdienst Kennisgroepen - Pricegiving after lending
- Belastingdienst Kennisgroepen - Excessive-loan edge cases
