Year-End Tips 2025: 19 Tips for the director – major shareholder (DGA)

 

Year-End Tips 2025: 19 Tax Tips for the director—major shareholder (DGA)

December is the ideal month to review which Dutch tax related actions you need to take before the end of the year or defer until the new year. Below, we provide you with the most important current tax tips for director-major shareholders (DGA). It’s a lot of information, but it can certainly be worthwhile to check! Need advice? We’re here to help!
 
1. Small-Scale Investment Allowance (KIA)
Have you invested enough in assets in 2025 to qualify for the small-scale investment allowance (see the table below)? If not, there may still be some tax benefits to be gained! To qualify for this investment scheme, an investment must be at least € 450 excluding VAT. Also, you are able to depreciate the amount invested annually.




Note! Did you make an investment in a business asset in 2020 and claim the small-scale investment deduction at that time? In the case of a potential sale within the five-year period, you must take into account a disinvestment addition. In such a case, consider postponing the potential sale until 2026.

2. Invest in energy-efficient business assets in 2025 (EIA)
Are you planning to invest soon in an asset listed on the energy list of the Dutch enterprise agency (RVO)? Assess whether this asset is also included on the Energy List for 2026. If not, it may be fiscally advantageous to invest in 2025. This means that, for example, you need to sign a confirmation of order or contract this year. However, you must ensure that the energy investment is reported to the RVO on time to claim the energy investment deduction and the environmental investment deduction.
3. Terminating fiscal unity by December 31, 2025

If you no longer wish that your entities will be part of a fiscal unity for corporate income tax as of January 1, 2026, the request for ending of the fiscal unity must be submitted before December 31, 2025. In certain cases, this can be advantageous when there are multiple profitable companies within a fiscal unity. This allows the companies to individually benefit from the lower ‘SME-bracket’ in corporate income tax. The rate difference between the first bracket up to € 200,000 (19%) and profit exceeding that amount (25.8%) is 6.8%.
The ending of a fiscal unity can also result in the application or increase of investment allowances.

Of course, there are also disadvantages to not being part of a fiscal unity for corporate income tax. Consider these pros and cons with an advisor before proceeding with a ending of this fiscal unity. Lastly, in case a fiscal unity is formed during 2025 and terminated before the end of 2025 this will result in a situation that this fiscal unity never existed.

Note! Consult with your advisor regarding any potential tax sanctions that may come into effect due to the termination of the fiscal unity.

4. Take advantage of the low tax bracket

Keep your BV’s profit below € 200,000 to benefit from the low tax bracket of 19%. Check where you can forward costs and defer revenues to save on corporate tax. For example, by using the cost equalization reserve (KER), the reinvestment reserve (HIR), provisions, or early depreciation. This prevents part of the profit from being taxed at 25.8%.The ending of a fiscal unity can also result in the application or increase of investment allowances.

5. Reduce tax interest

The tax interest rate for corporate tax is high (9% in 2025). Prevent the Tax Authorities from charging unnecessarily high interest by submitting and paying a provisional tax return on time. Has your company (BV) performed better than expected in 2025? If the (provisional) annual financial statements show that the BV will owe additional corporate tax for 2025? Request an adjustment to the provisional corporate tax assessment for 2025.

Note! A collective objection procedure against the level of this interest is currently in dispute with the Dutch court, which taxpayers can join. Recently, a Dutch court ruled that the calculated tax interest is not proportional and the amount of tax interest owed (then 8%) should be reduced to 4%. We recommend that you file an appeal against the tax interest stated on the tax assessment. In the case of a definitive assessment, the appeal must be submitted within six weeks of the date on the assessment. For a preliminary assessment, you must first submit a request to revise the tax interest. This request can be made up to six weeks after the date of the final assessment for that year. Recently, the Dutch Tax Authorities have indicated that, under certain conditions, it is possible to submit a combined letter in which a request for reduction is made while simultaneously filing an appeal against the rejection of that request. Of course, we can assist you with preparing a request for revision or an appeal.

6. Dividend payment in 2025 or wait for next year?

Dividend distributions to a director-major shareholder are taxed in box 2 in case he or she holds more than 5% of the shares in a B.V. or similar entity. For dividend income up to the first bracket of € 68,843 (for fiscal partners € 137,686), a rate of 24.5% will still be applied. For higher amounts of dividend income, the rate will remain at 31%.

7. Borrowing money from your private limited company (B.V.), including excessive lending

As a director-major shareholder (DGA), you can finance your investments with a loan from your B.V. The loan, like the investments, falls under box 3. The loan must be granted on arm’s-length terms, and one element of this is that it must be recorded in writing. Discuss with your advisor which conditions you need to agree upon. If the loan is related to your primary residence, under conditions the interest is deductible if the loan qualifies as a primary residence debt in box 1 based on the Dutch tax law.

If you, as a DGA, have a consistently high current account with your B.V., there is a possibility the Dutch Tax Authority will take the stance that (a part of) the debt needs to be regarded as dividend income and that they will make an adjustment, potentially even increased with a penalty. You can reduce this risk by ensuring there is a proper documentation.

Note! In recent years, the Dutch Tax Authorities have paid a lot of attention to loans between companies. If the loan is not provided at arm’s length terms, the loan is considered non-businesslike (i.e. low interest rate). A loan may not be considered at arm’s length if there is no repayment schedule agreed upon or if insufficient collateral has been provided to the creditor. If the loan is not at arm’s length, a loss on that loan is not deductible from the profit.

Note! Are you borrowing money from your B.V.? You may then be confronted with the ‘excessive lending’ legislation. The legislator argues that directors-majority shareholders (DGA’s) are borrowing too much from their own BV and wants to limit this. However, there is a certain threshold, and only debts above this amount are considered excessive. The excessive part is then taxed in box 2 at the applicable rates. Since 2024, a threshold applies, and under this law you and any fiscal partner may together borrow a maximum of € 500,000 tax-free from your own company. Loans below the € 500,000 threshold do not constitute a “safe haven”. Recently a Dutch lower court decided that also in case the outstanding loan amount was lower than € 500,000 this could be regarded as taxable withdrawal instead of a loan. This may occur if, at the time the loan is granted, it is already certain or almost certain that the borrowed funds cannot or will not be fully repaid. Therefore, it is essential that the loan is agreed on a businesslike basis, similar to a bank loan, and that repayment actually takes place. Loans for the purchase of a primary residence are exempted and are not included in the calculation. The reference date for 2025 is December 31, 2025. You have until this date to repay debts above the threshold.

Tip! Please check before December 31, 2025, whether your total debt amount to the company exceed the threshold amount € 500,000. The exceeding amount of the loan will be taxed in box 2 at 24.5% or 31% (depending on the amount). Depending on your situation, it may be advantageous to repay part off or the whole debt amount, while in other situations taxation in box 2 could actually be beneficial. Consult your advisor to determine the most appropriate approach for your situation.

8. Provision

If you want to defer profits, consider whether you can create a provision. It is sufficient for this purpose that future expenditures have their origin in facts and circumstances that occurred before the balance sheet date, and that there is a reasonable degree of certainty that the expenditures will be made in the future. Furthermore, future expenditures must also be attributable to the period preceding the balance sheet date. Possible provisions are, for example, restructuring, maintenance, remediation costs, providing guarantees on products of anniversary expenses for employees.

9. Increased additional taxable income for electric cars

When a car is provided to you or your employee and this car may also be used for private purposes, this benefit will be taxed. The employer then applies an addition of 22% on the car’s car value as additional taxable income. For electric cars, this addition will change in the coming years: in 2026 it will be 18% on the first € 30,000 (2025: 17%), in 2027 20% on € 30,000, and as of 2028 the difference will disappear entirely. New electric cars will then have the same rate as new non-electric cars: 22% on the car value. Consider purchasing an electric car or arranging a lease before the end of this year to take full advantage of the lower additional income: 17% on the first € 30,000 and 22% on the excess for 60 months. For cars purchased in 2026, the 18% addition also applies for 60 months.

Tip! Does your current lease arrangement for your company electric car, or your employee’s lease, end in 2026? Calculate whether terminating the current lease and entering into a new contract would be more advantageous.

10. Penalty tax for non-electric company cars

From 2027, an additional penalty levy is likely to be introduced for non-electric passenger’s cars provided to employees for private use. This penalty amounts to 12% on the car value (including VAT and BPM) and will be applied to all non-electric passenger cars (including hybrid vehicles) made available to employees for business purposes and that may also be used privately. Commuting to and from work will also be considered as private use for this penalty, differing from regular payroll tax rules.

For cars older than 15 years, the value bases for the penalty levy will be based on the market value. This levy will not apply to van’s or trucks (except for passenger vans used for care transport). The final levy can not be passed on to the employee.

Note! There is a transitional law for non-electric company cars which are provided to the employee before 2027. In that case the penalty tax is not applicable before September 17, 2030.

Tip! Assess your ongoing lease arrangements in 2026 so that you may benefit from the transitional law until September 17, 2030. In addition, as an employer, you may consider adjusting employment terms or mobility arrangements.

11. Final wage tax return 2025

Verify whether all payments made to your employees have been correctly accounted for. Also consider aspects such as fictitious additions for a company car and/or vans, as well as other favorable forms of compensation, such as the work-related cost scheme (see our next tip).

12. Make full use of the possibilities within the work-related cost scheme (WKR)

For 2025, optimize the possibilities within the work-related cost scheme. The percentage for calculating the free space remains 2% for the first € 400,000 of the fiscal wage sum and 1.18% for the amount exceeding this.

Tip! Evaluate whether you still have any remaining free space in 2025 and consider whether items you plan to reimburse or provide in 2026 can possibly be reimbursed or provided in 2025.

13. Tax-free travel and homeworking allowances

If you do not provide a company car to your employee, but the employee commute from home to work and vice versa, you can tax-free reimburse the employee up to a maximum of € 0.23 per km. It does not matter how the employee travels. This applies to both commuting as well as business travel. For public transport, you may also reimburse the actual costs.

You can also tax-free reimburse your employees a tax-free allowance up to € 2.40 per day in case an employee works from home to cover additional costs occurred by working from home.

Note! You may not provide both a tax-free travel allowance and a homeworking allowance on the same day.

14. 30% ruling in 2026 and reduction of tax-free reimbursement of actual extraterritorial costs for incoming employees

Employees who are recruited from outside the Netherlands to work in the Netherlands often incur double costs (extraterritorial costs). Under certain conditions, an employer may reimburse these costs tax-free. This can be done on an expense reimbursement basis, where the actual costs are reimbursed. However, it is simpler (and often more advantageous) to reimburse 30% of the total salary tax-free (without further proof).
The Dutch government has proposed that, as of January 1, 2026, the tax-free reimbursement of extraterritorial costs for incoming employees will be restricted. This means that additional living costs, including gas, water, electricity, and other utilities related to temporary residence in the Netherlands, as well as extra private phone call costs with the country of origin, can no longer be reimbursed tax-free. If the employer does reimburse these costs, the payment will generally be treated as taxable income.

Tip! Assess which extraterritorial costs you currently reimburse and whether they can still be reimbursed tax-free in 2026.

From 2024, the 30% ruling may only be applied up to the so-called Balkenende norm (2025: € 246,000, 2026: € 262,000). Any amount exceeding this limit is not eligible for the 30% ruling. It is still possible, however, to reimburse the actual costs instead of applying the 30% ruling. For both the 30% ruling and reimbursement of actual costs, the maximum total duration period is five years (previous periods of residence in the Netherlands may reduce this period). In addition, the actual costs of an international school can still be reimbursed alongside the 30% ruling.

Note! Request for the 30% ruling within four months after starting date of your employment so that the ruling can be applied retroactively to this starting date. If the request is submitted later to the Tax Authorities, the 30% ruling may not be applied retroactively to the starting date and can only be applied from the first day of the following month of the request.

Tip! When changing employers, there is a right to continue the 30% ruling. On the condition that there is less than three months between the two employments. Continuation of the 30% ruling can be requested within four months after the starting date of the new employment.

Reduction of the 30% ruling from 2027
It is proposed that as per 2027 the 30% ruling percentage will be reduced from 30% to 27%. Additionally, the minimum income requirement will increase from € 46,107 to € 50,436. For incoming employees younger than 30 years with a master’s degree, the income requirement will be € 38,338 (2027). For employees for whom the 30% ruling was applied before 2025, the 30% rate and the current (indexed) salary thresholds will continue to apply for the entire duration of the ruling.

As of 2025, the partial non-resident tax liability is abolished. Previously, employees with the 30% ruling could choose to be treated as partial non-resident tax payer in the Netherlands when filing a Dutch income tax return. Even though they lived in the Netherlands, they were considered a foreign tax resident for box 2 and box 3, meaning they only had to report Dutch real estate in box 3 and were not liable for Dutch taxes on their (worldwide) bank and savings accounts or shares portfolio. Inform newly arrived employees about this change. If an employee has already benefited from the 30% ruling in 2023, a transitional law will be applicable. For this group of employees, the partial non-resident tax liability will remain in effect until December 31, 2026.

15. Last VAT return of the fiscal year 2025
When preparing the final VAT return for the year 2025, please consider the following points.
 
Adjustments related to private usage:
• Correction of VAT for private use of a car (both for you as an entrepreneur as well as your employees).
• Correction of VAT for private use, for example, gas, water, electricity, and heating.
• Correction of VAT for personal usage of goods belonging to the business for purposes other than businesslike (including private use, such as assets used for both business and personal purposes).
• Correction of VAT for services provided by you as an entrepreneur for purposes other than business (including private usage).
• Correction within the framework of the company canteen scheme.
• Other corrections on the deduction of prepaid taxes on distributions to employees (providing opportunities for sporting or recreation, private transportation, and housing), as well as for business gifts and similar items.
 
Pro-rata-related adjustments:
• Entrepreneurs who do not exclusively provide VAT-taxed services must calculate the pro-rata deduction percentage for the past year. This may result in an adjustment (upwards or downwards) of the previously deducted VAT on general costs.
• If the pro-rata deduction percentage falls below 90% (or 70% for, among others, travel agencies), you must assess the implications for possible ‘optional taxed rental’ in rental contracts.
• Revision of prepaid tax on movable and immovable investment goods.
In some cases, under conditions, it has been approved that corrections can be made at the end of the calendar year (if the calendar year is not the same as the fiscal year).
 
Deadline for reclaiming foreign VAT: 
Are you economically active in multiple EU countries? Dutch entrepreneurs who have tax deduction entitlement can reclaim VAT paid in other EU countries through an electronic request with the Tax Authorities. Note that separate login details are required for this, and the application process may take several weeks. The request must be submitted no later than September 30 of the year following the year for which you are reclaiming VAT. Received requests after this date may not be taken into account by the other EU country.
16. Does a debtor not pay your invoices? Request for VAT refund in a timely manner

If a debtor does not pay your invoice, you may, under certain circumstances, request for a refund of the VAT you have already paid to the Tax Authorities.

Note! If you make arrangements with your debtor regarding the payment of your invoice(s), your claim may be converted into a loan. In that case, you cannot submit a refund request to the Tax Authorities. Before proposing a payment scheme, make sure to carefully assess whether your debtor will ultimately fulfil his obligations or not. You must submit the refund request in a timely manner. This means within one month after it becomes clear that your customer will not pay your invoice. Ultimately, one year after the claim became due and payable, it is assumed that the debtor will not pay your invoice, and you must request the VAT refund.

17. Retention obligations

Cleaning up and destroying old administrative records can certainly result in cost savings, but keep in mind the legal retention period of at least seven years for your administrative data. Regarding real estate and the rights subject to it, you must keep the VAT administration for ten years. For VAT, there is a special retention obligation in certain cases (for ten years). Permanent documents (deeds, pension and annuity policies, etc.) should not be discarded.

Tip! If you store the data from sales receipts digitally and are able to make it available for the Tax Authorities, it is no longer necessary to keep paper receipts, cash register rolls, and similar information. This also applies to invoices, provided that no information is lost during scanning.

18. Reporting of payments made to third parties

Starting from January 1, 2022, employers are required to provide information to the Tax Authorities about paid amounts without wage tax withholding to third parties. If you make such payments to a private person, you must inform the Tax Authorities about several details, including name, address details, place of residence, date of birth, Citizen Service Number (BSN), and the amounts paid, including expense allowances, in a calendar year. The provision of information obligations does not apply to payments to employees, artists, professional athletes, or volunteers, among others. The provision of information obligations also does not apply to individuals who have issued an invoice, provided that the invoice complies with the requirements of the Dutch VAT law.

Tip! Start as soon as possible with identifying which individuals you will need to gather and provide information for and check if you have all the required information, such as a BSN number.

19. Update of SBI-codes

In September 2025, the Dutch Chamber of Commerce (Kamer van Koophandel) significantly updated the Standard Industrial Classification (SBI) codes. These codes are important for insurance, pensions, collective labor agreements (CAO’s), subsidies, and financing. Since many existing codes have been amended, merged, or replaced, it is important to review the description of your business activities and correct it if necessary. An incorrect SBI code may lead to incorrect premiums, missed subsidy opportunities, or an incorrect CAO affiliation. Therefore, carefully check your information and submit a correction request to the Chamber of Commerce if needed.

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