Dividend in 2026 or 2027? What the proposed lower box 2 rate means for DGAs

What Changed on 29 September, and What It Means

The question only became interesting because of what happened between 15 and 29 September. On Prinsjesdag, the cabinet filed the Belastingplan 2027 with box 2 unchanged: 24.5% in the first bracket and 31% in the second, with the first bracket limit indexed from 68,843 euros to 69,607 euros per person. On 29 September, a letter to the Tweede Kamer announced supplementary proposals. The second bracket would fall from 31% to 29.2% for the four years 2027 to 2030, and return to 31% from 2031. The first bracket stays at 24.5%.

None of this is law. The proposals still have to be put into legislation and pass both chambers, and the cabinet, a minority cabinet of D66, VVD, and CDA, has no majority for its tax package yet. The Tweede Kamer resumes the debate on 26 October and votes on 12 November, and the Eerste Kamer follows. Reports say the largest left-wing opposition party objects to a lower rate for DGAs, while parties on the right want lower income tax in return for their support. Treat the proposals as real but uncertain. The useful question is which choices still look sensible if they fail.

The lower rate does not come alone. The same letter proposed lowering the excessief lenen limit, the amount a DGA and fiscal partner can owe their BV without box 2 tax, from 500,000 euros in five steps of 80,000 euros: 420,000 euros on 31 December 2027, then 340,000, 260,000, 180,000, and 100,000 euros in 2031. A loan for your own home with a hypotheekrecht for the BV stays outside the count. The cabinet says the temporary lower rate is meant to encourage DGAs to take capital out of their BV, and the package helps finance the accelerated move to a tax on realised gains in box 3.

Key takeaway: None of the 29 September proposals is law yet. If they pass, the second box 2 bracket drops to 29.2% for 2027 to 2030, and the borrowing limit falls from 500,000 euros to 420,000 euros on 31 December 2027, ending at 100,000 euros in 2031. The first lower limit applies on 31 December 2027, so the 2026 decision is mainly about the first bracket, and the real work for DGAs with RC debt starts in 2027.

The wider fiscal context of the Prinsjesdag package is in Belastingplan 2027 Prinsjesdag.

2026 vs 2027: The Numbers Side by Side

Comparing the two years takes three columns rather than two, because 2027 has two versions: what was filed on Prinsjesdag and what was proposed on 29 September.

The proposed cut is 1.8 percentage points on every euro that falls in the second bracket. On a gross second-bracket dividend of 100,000 euros it is worth 1,800 euros, and on 500,000 euros it is worth 9,000 euros. Here is the 100,000-euro case in full. In 2026, the BV withholds 15,000 euros of dividendbelasting, the box 2 liability is 31% of 100,000, which is 31,000 euros, and the 15,000 euros withheld is credited, leaving 16,000 euros to pay through the income tax return. The total burden is 31,000 euros, and 69,000 euros is left. In 2027 at the proposed rate, the liability is 29,200 euros, 14,200 euros is paid through the return, and 70,800 euros is left. The dividendbelasting is a prepayment and not an extra tax.

The BV pays VPB before any dividend exists, so the rate that matters to a DGA is the combined one. At the 19% VPB rate, profit extracted in the second bracket is taxed at 19% plus 81% of 31%, which is 44.11%. At 29.2% it is 42.65%, so the 1.8-point cut becomes a 1.46-point cut in the combined rate. Above 200,000 euros of profit, VPB is 25.8%, which raises the combined rate further. How salary and dividend compare on this basis is covered in DGA salary vs dividend, and the VPB calculation that comes first is in commercial vs fiscal profit Dutch BV.

Scenario A: You Have Winst Reserves and No Large RC Debt

For a DGA whose BV holds substantial retained profit, owes little or nothing in RC, and has not yet touched the 2026 first bracket, the first move does not depend on waiting. The first bracket is use-it-or-lose-it. The 68,843 euros per person at 24.5% does not carry into 2027, where a fresh 69,607 euros arrives on 1 January. Taking dividend up to the limit before 31 December costs nothing extra, and the 764-euro difference in the 2027 limit is worth only about 50 euros. Fiscal partners can divide box 2 income between them in their returns, so both first brackets can be used even if only one partner holds the shares. An extra first bracket is worth about 4,475 euros in 2026 on a large distribution, which is 6.5 points on 68,843 euros.

The rate cut only matters for the part above the first bracket. Take a gross distribution of 300,000 euros to a single DGA with no other box 2 income. In 2026, the box 2 liability is about 88,525 euros. At the proposed 2027 rates, it is about 84,330 euros, so the saving is about 4,200 euros. Almost all of that comes from the proposed rate cut, since the same distribution at the 2027 rates as filed would cost about 88,480 euros, in line with 2026. That is real money, but it is under 1.5% of the distribution.

In practice, the work is short. Add up the box 2 income already received in 2026, including any share sale. Check how much cash the BV can pay out. Decide how to divide the income between fiscal partners in the return. Then adopt the uitkeringsbesluit before 31 December. A DGA who does these four things in November has used the cheapest capacity of the year, whatever happens to the proposals in the Tweede Kamer.

The decisive constraint is often liquidity, not rates. A BV may only distribute if it can keep paying its debts afterwards, and a balance sheet showing large reserves does not mean there is cash. A uitkeringsbesluit has to be adopted before the dividend counts in the year. A DGA with reserves but little cash is limited by what the BV can pay, not by the tax rate.

Scenario B: You Have Significant RC Debt

For a DGA whose RC debt sits between roughly 400,000 and 500,000 euros, the proposals matter in a different way. A DGA owing 450,000 euros today is safely under the 500,000-euro limit. If the proposed 420,000-euro limit applied on 31 December 2027, the same DGA would have 30,000 euros of excess without borrowing a single euro more. The limit moved, not the debt.

The deadline for that is 31 December 2027, not 2026, so there is a full year to act, and the 2026 first bracket is a cheap way to begin. The excess is taxed as if it were dividend, but only once. Whatever has been taxed in an earlier year stays out of the count later. A DGA owing 480,000 euros would have an excess of 60,000 euros on 31 December 2027, taxed at about 14,700 euros if it falls within the first bracket. In 2028 the proposed limit is 340,000 euros, the excess is 140,000 euros, and only the new 80,000 euros is taxed. The same applies in each following year. At the proposed rates, 80,000 euros costs about 20,100 euros when it is the only box 2 income of the year.

The options for reducing the debt differ in cost. Repaying from private money or contributing assets to the BV carries no box 2 tax. Raising salary to repay is expensive, because wages are taxed at up to 49.5%. Distributing dividend and setting it off against the RC is attractive when the DGA wants to extract profit anyway, because it uses the 24.5% bracket. The RC falls by the net dividend, after the 15% withholding, so a gross dividend of about 70,600 euros reduces an RC of 480,000 euros to 420,000 euros, at a box 2 cost of about 17,300 to 17,400 euros if it falls in the first bracket. A debt for your own home can be formalised with a hypotheekrecht for the BV, which takes it out of the count. Borrowing from your own BV explains the mechanics in full.

Watch out: The limit is measured on 31 December each year. A DGA who repays below the limit in the spring and draws again before year-end is assessed on the 31 December balance. The reduction has to be in place on that date, not achieved briefly during the year.

Scenario C: You Are Already in the Second Bracket in 2026

A DGA who has already taken box 2 income above 68,843 euros in 2026, through earlier dividend or the sale of shares, faces 31% on every further euro this year. For this DGA, waiting is the clearest case. Suppose 100,000 euros more is to be distributed. In 2026 it costs 31,000 euros. In 2027, the first bracket is fresh: 69,607 euros at 24.5% is 17,054 euros, and the remaining 30,393 euros costs 9,422 euros at 31%, or 8,875 euros at the proposed 29.2%. The total is about 26,476 euros if the proposal fails, and about 25,929 euros if it passes.

The saving from waiting is therefore about 4,500 euros even if the lower rate fails, and about 5,070 euros if it passes. Most of the benefit comes from the bracket resetting, not from the rate cut. If the proposal fails, waiting costs nothing in rate terms, because the second bracket is 31% in both years. The real costs of waiting are elsewhere: the money stays in the BV, and rules can change again. A DGA who needs the cash now has to weigh that against roughly 4,500 euros per 100,000 euros distributed.

The Falling Threshold: How the Numbers Move Each Year

The pace of the proposed reduction matters more than the end point. Each 80,000-euro step creates a new limit on 31 December of that year. A DGA who has not planned around it moves from compliant to non-compliant without borrowing anything new.

The 2027 limit of 420,000 euros affects only DGAs owing more than that, a fairly small group today. Each step then brings more people in. At 340,000 euros in 2028 and 260,000 euros in 2029, a DGA who has used the RC to fund living costs, investments, or a home would be affected. At 180,000 euros in 2030 and 100,000 euros in 2031, the RC would no longer work as a long-term financing vehicle. Because the excess is taxed only once, the pain is spread: a DGA owing 480,000 euros would have 380,000 euros of excess by 2031, taxed in steps of 60,000 euros and then 80,000 euros a year.

The political uncertainty makes a plan that survives both outcomes worth more than a bet on one. Filling the first bracket each year, formalising a home loan with a hypotheekrecht, and keeping a clear record of the RC balance make sense whether or not the vote succeeds. Only two things depend on it: the 1.8-point cut in the second bracket, and the exact schedule of the limit. If parliament passes one proposal and amends the other, the numbers above will need updating, but the logic of using each year's capacity does not change.

The window for acting at the proposed lower second-bracket rate is 2027 to 2030, which matches the four years of the cut. The cabinet's intention is explicit: it wants DGAs to take capital out of their BV and repay RC debt. For a DGA with both large reserves and a large RC, the sensible starting point is a multi-year plan, not a single year-end move. Each year, use the first bracket for both partners, compare the repayment routes above, and measure the position against that year's limit on 31 December. The year-end side of this, including the RC balance, is covered in year-end tax planning Dutch BV founders. If you want your RC balance and distributions tracked against the limits through the year, book a demo, or see how bookkeeping and payroll works for a BV. We can also help you incorporate your BV.

FAQs

What is the box 2 tax rate in 2026?

24.5% on the first 68,843 euros of box 2 income per person, and 31% above that. The BV withholds 15% dividendbelasting, which is credited against the box 2 liability.

What is the proposed box 2 rate in 2027?

The Belastingplan 2027 as filed keeps 24.5% up to 69,607 euros and 31% above. A supplementary proposal of 29 September 2026 would lower the second bracket to 29.2% for 2027 to 2030. The proposal is not law.

When was the box 2 rate reduction announced?

On 29 September 2026, in a letter from the cabinet to the Tweede Kamer, two weeks after the Belastingplan 2027 was filed on Prinsjesdag.

Has the lower box 2 rate been passed into law?

No. The cabinet is a minority cabinet and has no majority for its tax package yet. The Tweede Kamer votes on 12 November, and the Eerste Kamer must approve afterwards. The proposals could still change.

Should I take dividend in 2026 or wait for 2027?

It depends on your situation. Use the 2026 first bracket now if you have not used it, because it does not carry over. If you are already in the second bracket in 2026, waiting saves about 4,500 euros per 100,000 euros through the bracket reset, and more if the lower rate passes. If you have large RC debt, start planning for 2027.

What is the excessief lenen threshold and how does it change from 2027?

It is the amount a DGA and fiscal partner can owe their own BV on 31 December without box 2 tax: 500,000 euros in 2026. The proposal lowers it to 420,000 euros on 31 December 2027, then 340,000, 260,000, 180,000, and 100,000 euros in 2031. Loans for your own home with a hypotheekrecht stay outside the count.

Does the excessief lenen threshold reduction apply even if I do not borrow more?

Yes. If the proposal passes, a debt that was below the limit one year can exceed it the next without any new borrowing. The excess is taxed as dividend, but only once; what has been taxed before stays out of the count in later years.

What is the best strategy for a DGA with large RC debt and large winst reserves?

Plan across several years. Use the first bracket for both fiscal partners each year, repay through dividend set-off, private money, or asset contributions as suits your liquidity, formalise any home loan with a hypotheekrecht, and check the balance on every 31 December. Fiscaal partnerschap Netherlands explains how partners can divide box 2 income.

How long does the proposed lower box 2 rate last?

Four years, 2027 to 2030. From 2031, the second bracket would return to 31%.

What is the combined effective tax rate on BV profit extracted as dividend?

At the 19% VPB rate, 38.85% in the first bracket and 44.11% in the second bracket in 2026. At the proposed 29.2% second-bracket rate, 42.65%. Above 200,000 euros of profit, VPB is 25.8%, and the combined rate is higher.