Ten tax moves Dutch BV founders should make before 31 December 2026

Move 1: The RC Balance

The most urgent item on a DGA's December checklist is the rekening-courant balance. Under the Wet excessief lenen, the combined debt a DGA and their fiscal partner owe to their own BV or BVs is measured on a single date: 31 December. Cross 500,000 euros on that date and the excess is taxed as a deemed dividend in box 2, regardless of what the balance looked like at any other point during the year.

A DGA carrying 600,000 euros in RC debt on 31 December 2026 faces an excess of 100,000 euros. Under 2026 box 2 rates, the first 67,000 euros of that excess is taxed at 24.5%, 16,415 euros, and the remaining 33,000 euros at 31%, 10,230 euros, for a total of 26,645 euros in box 2 tax on money that never actually left the business as cash.

Five reduction strategies exist, and all of them need weeks of lead time rather than a single December phone call. Offsetting a declared dividend against the debt reduces the balance without moving actual cash. Raising DGA salary and using the net proceeds for a genuine bank transfer repayment works too, though it carries its own loonheffingen cost. Formalising a hypotheekrecht on any portion of the debt that funded the DGA's own home removes that portion from the calculation entirely, but only if the notarial deed is actually registered before year-end. Contributing personally owned assets into the BV at a defensible valuation reduces the debt by the same amount. And formally offsetting any amount the BV separately owes the DGA against the RC balance closes the gap from the other direction.

Key takeaway: The RC peildatum is 31 December, not a year-average, not an estimate. A DGA with 510,000 euros in RC debt on 31 December 2026 owes box 2 tax on 10,000 euros regardless of what happened between January and November. Check the balance today.

The full mechanics of this threshold, including how it interacts with amounts already taxed in prior years, are covered in borrowing from your own BV.

Move 2: Dividend Timing

Dividend taken in 2026 and dividend taken in 2027 are taxed at identical rates, but they are not fiscally equivalent, and the reason comes down to a single number: the 68,843-euro threshold that separates the 24.5% bracket from the 31% bracket resets every calendar year. Distribute up to that threshold in 2026 and up to the same threshold again in 2027, and a DGA accesses the low rate twice rather than once.

The arithmetic makes the difference concrete. Distributing 134,000 euros entirely within 2026 produces 24.5% on the first roughly 67,000 euros, 16,415 euros, and 31% on the remaining 67,000 euros, 20,770 euros, for a total of 37,185 euros in box 2 tax. Splitting the same 134,000 euros as 67,000 euros in 2026 and 67,000 euros in 2027 produces 16,415 euros in each year, 32,830 euros combined, a saving of roughly 4,355 euros purely from timing. A fiscal partner doubles this planning room further: where both spouses hold shares, each gets their own threshold, meaning a couple can distribute up to 137,686 euros combined in a single year at the low rate.

The decision genuinely depends on year-to-date box 2 income. A DGA who has already distributed dividend earlier in 2026, or triggered a box 2 event some other way, is likely already inside the 31% bracket, and any further 2026 distribution lands there too; deferring to 2027 for a fresh threshold is usually the better move in that specific case. The formal uitkeringsbesluit, the distribution resolution, needs to be adopted before 31 December for a distribution to actually count in the 2026 tax year. None of this applies to dividend moving between a werkmaatschappij and its own holding company, which stays entirely tax-free under the deelnemingsvrijstelling regardless of timing; the bracket calculation only matters once money actually reaches the DGA personally. DGA salary vs dividend covers how this timing decision fits into the broader salary-versus-dividend trade-off.

Move 3: Box 3 Before 1 January

Box 3 is measured on 1 January 2027, which means the action window for reducing the 2026 box 3 liability is closing now rather than at the calendar year's own end. Whatever savings, investments, and other box 3 assets exist on that single January date determine what gets taxed for the whole of 2026.

The mechanics are straightforward: a heffingsvrij vermogen of roughly 57,684 euros per person, 115,368 euros combined for fiscal partners, sits entirely outside the calculation. Above that threshold, a 6.00% deemed return applies to overige bezittingen, taxed at 36%, working out to an effective 2.16% of asset value each year regardless of what that asset actually earned. Practical reduction moves before year-end include repaying outstanding personal debts, since net wealth rather than gross assets determines the box 3 base, moving liquid savings into a BV before 1 January where the personal-versus-BV analysis favours it, and simply making a large planned purchase, a renovation, a vehicle, before 31 December rather than waiting until January, since spending the money removes it from the box 3 base entirely on either side of the date.

Fiscal partners have an extra lever worth using specifically: distributing shared wealth between the two partners' own returns to make sure both individual heffingsvrij thresholds actually get used, rather than concentrating everything under one partner's name and wasting the other's exemption. And 2026 is the last full year to benefit from the groenbeleggingsvrijstelling, the green investment exemption, at anything close to its current value, since it shrinks substantially in 2027 and disappears by 2028. Before box 3 changes in 2028 covers how this final year under the current system connects to the broader 2028 transition.

Move 4: Use the WKR Now

The werkkostenregeling vrije ruimte has no carry-forward. What is not spent by 31 December 2026 simply disappears; there is no mechanism to roll it into 2027.

For 2026, the vrije ruimte sits at 2.00% of the first 400,000 euros of fiscal wage bill, plus 1.18% above that. A BV with a 200,000-euro wage bill has roughly 4,000 euros of genuinely tax-free room to spend on staff benefits before the year closes, staff gifts, a Christmas package, a year-end bonus routed through WKR rather than ordinary salary, equipment, fitness subscriptions, workplace parking. From 2027, the vrije ruimte rises to 2.16% on that first bracket, which is worth factoring into next year's planning even though it does nothing for the balance expiring this December.

Watch out: Gifts to employees above 25 euros per occasion do not automatically qualify for a gerichte vrijstelling. Booking a 60-euro gift as WKR-vrij does not make it tax-free on its own; it simply consumes vrije ruimte instead, and if that ruimte is already exhausted, the excess triggers an 80% eindheffing. Check the running WKR balance before committing to any December staff spending.

The branche-eigen producten exception, the staff-discount allowance common in retail and hospitality, disappears entirely from 2027, which is worth planning around now if your business currently relies on it. Whether a CAO governs some of these staff benefit decisions in the first place is worth checking too; CAO Netherlands employer covers how that collective agreement layer interacts with WKR spending.

Moves 5 and 6: Two Quick Payroll Fixes

Two payroll corrections should happen inside the December 2026 run specifically, before the loonheffingen year formally closes.

The kilometervergoeding correction is the smaller of the two but genuinely time-sensitive. The tax-free business mileage rate rose from 0.23 euros to 0.25 euros per kilometre, applied retroactively to 1 January 2026 through a ministerial policy decree published in May 2026. Any employer, including a DGA reimbursing their own business travel, still paying the old rate owes a correction of 0.02 euros per kilometre going back to January; for someone driving 800 business kilometres a month, that cumulative shortfall already reaches roughly 192 euros by December. Processing this in the December payroll run, rather than letting it slip into next year, keeps the correction inside the 2026 aangifte loonheffingen where it belongs.

The DGA salary and voorlopige aanslag check covers two separate things at once. First, confirm the DGA's own salary actually meets the 58,000-euro gebruikelijk loon minimum for 2026; a salary that quietly drifted below this figure gets flagged as one of the very first items in almost any Belastingdienst loonheffingen audit, and grossing it up before year-end is far cheaper than a naheffing discovered later. Second, compare the BV's actual expected 2026 profit against whatever provisional VPB assessment is currently on file. If the real profit is running significantly ahead of that provisional figure, belastingrente at 5.0% a year starts accruing from six months after year-end on the underpaid difference; requesting an upward adjustment now through Mijn Belastingdienst Zakelijk limits that interest considerably, and the reverse adjustment applies if profit is actually coming in lower than expected. Payroll errors Dutch employers covers the mileage correction and the gebruikelijk loon check in more operational detail, and provisional tax assessment Netherlands covers exactly how to request that voorlopige aanslag adjustment.

Moves 7 and 8: Investment and Cars

Two investment decisions carry genuinely opposite year-end logic, and getting them backwards costs real money either way.

For ordinary KIA-qualifying investments, equipment, vehicles, most non-energy business assets, the standard advice holds: buy before 31 December to claim the deduction in the 2026 VPB return rather than waiting for 2027. The KIA rate itself sits at 28% for qualifying investment between 2,900 and 69,765 euros in the year, tapering above that ceiling, so it is worth checking whether a planned December purchase would push total qualifying investment for the year past that upper threshold before committing to the timing.

Energy-efficient assets on the official energielijst run the opposite way entirely. The EIA rate itself rises from 40% in 2026 to 45.5% in 2027. On a 50,000-euro qualifying purchase, buying in December 2026 produces a deduction of 20,000 euros, worth roughly 3,800 euros in VPB saving at 19%; waiting until January 2027 produces a deduction of 22,750 euros, worth roughly 4,323 euros, a genuine 523-euro improvement purely from waiting five weeks. For any energy-efficient asset that is not urgently needed before year-end, deferring the purchase into January 2027 is the better call, and this is exactly the kind of nuance most year-end tax guides get backwards by defaulting to "buy before December" advice that only applies to the non-energy category.

The company car decision carries the largest single number in this whole article. A pseudo-eindheffing of 12% applies from 2027 to new fossil-fuel company car assignments, calculated on the vehicle's cataloguswaarde and charged to the employer, not the employee. A diesel car worth 45,000 euros assigned under a new arrangement in 2027 costs the employer 5,400 euros a year in this levy alone, 16,200 euros over a typical three-year lease, on top of whatever the car itself already costs. Existing arrangements already in place before 2027 carry transitional protection through 16 September 2030, and an electric equivalent avoids the pseudo-eindheffing entirely, with the employee instead paying bijtelling at 16% on the first 30,000 euros of cataloguswaarde and 22% above that. Anyone planning to provide a new company car in 2027 should place that order now for an electric vehicle, or confirm with the leasing company that a fossil-fuel arrangement genuinely starts before 1 January 2027 to qualify for the transitional protection at all. Belastingplan 2027 covers where both the EIA increase and the pseudo-eindheffing sit inside the broader 2027 package.

Moves 9 and 10: Pension and Startersaftrek

Two less urgent but potentially higher-impact moves round out the list, worth checking specifically for the right kind of DGA rather than assuming they apply universally.

A lijfrente deposit made before 31 December 2026 is deductible in box 1 against the DGA's own salary income in the year it is paid. The jaarruimte, the maximum deductible amount, is calculated as 30% of 2025 pensioengrondslag-eligible income minus a factor for existing pension accrual, and a reserveringsruimte allows unused jaarruimte from as far back as the past ten years to be caught up in a single year, capped at roughly 38,576 euros for 2026. For a DGA with little or no existing pension provision and a meaningful salary, the tax saving at the top marginal rate on a 20,000-euro lijfrente deposit runs close to 9,900 euros, deferred rather than eliminated, since the eventual retirement income is taxed too, typically at a lower rate. This move is specifically for DGAs building genuine long-term retirement provision, not a general-purpose year-end tax reducer for everyone.

The startersaftrek move comes with an important qualification worth stating plainly: it applies to IB-ondernemerschap, not to a pure DGA structure running entirely through a BV. It becomes relevant specifically for a DGA who also runs a concurrent eenmanszaak or ZZP practice alongside their BV, or who is still within their first years as an IB-ondernemer in some other capacity. At 2,123 euros in 2026, the startersaftrek is available at its full current value this year; it shrinks in 2027 and disappears entirely from 2028, meeting the 1,225-hour urencriterium and falling within the first three qualifying years of entrepreneurship for that specific activity.

These ten moves interact rather than sitting independently. Distributing a dividend to reduce the RC balance in Move 1 also creates box 2 income that directly affects the bracket calculation in Move 2, and the box 3 decisions in Move 3 change depending on whether that dividend actually left the BV or stayed inside it. Coordinating these decisions together, rather than executing each one in isolation, is where a proper year-end review with a tax advisor genuinely earns its cost. Neno's bookkeeping and tax service coordinates exactly these year-end decisions inside the same platform that already handles the full year's administration, rather than treating December as a separate, disconnected exercise.

FAQs

What is the most important tax deadline for a Dutch DGA before 31 December?

The rekening-courant peildatum for the excessief lenen threshold is generally the single most consequential deadline, since it triggers an automatic box 2 tax event based purely on the balance at that one date, regardless of intent or explanation.

What happens if my rekening-courant balance exceeds 500,000 euros on 31 December 2026?

The excess above 500,000 euros, combined across the DGA and any fiscal partner, is taxed as a deemed dividend in box 2 for that year, at 24.5% up to roughly 68,843 euros and 31% above, even though no actual cash distribution took place.

Should I take dividend from my BV before or after 31 December 2026?

It depends on year-to-date box 2 income. If you have not yet used your 2026 low-rate bracket, distributing before year-end makes sense; if you have already used it, deferring to January 2027 accesses a fresh bracket instead.

What is the box 3 peildatum and why does December matter?

Box 3 wealth is measured on 1 January 2027, which reflects the position at year-end 2026. Reducing net wealth before 31 December, through debt repayment or planned spending, is what actually lowers the 2026 box 3 liability.

What happens to my WKR vrije ruimte if I do not use it before year-end?

It simply expires. There is no carry-forward mechanism into 2027, so any unused portion of the annual budget is permanently lost once the calendar year closes.

What is the DGA gebruikelijk loon minimum in 2026?

58,000 euros gross per year, or the salary of the highest-paid comparable employee if that figure is higher. A salary below this minimum is one of the first items checked in a Belastingdienst loonheffingen audit.

Should I buy energy-efficient equipment before or after 31 December 2026?

Generally after, if the purchase is not urgently needed. The EIA rate rises from 40% in 2026 to 45.5% in 2027, meaning a January 2027 purchase produces a larger fiscal deduction than an identical purchase made in December 2026.

Why should I order an electric company car before year-end?

Because a fossil-fuel car assigned under a new arrangement from 2027 triggers a 12% employer-side pseudo-eindheffing on the cataloguswaarde, while an electric equivalent avoids that levy entirely and existing pre-2027 arrangements carry transitional protection.

Can I deduct a lijfrente deposit in 2026?

Yes, against box 1 salary income, up to the calculated jaarruimte plus any unused reserveringsruimte from the past decade, provided the deposit is actually made before 31 December 2026.

Does the startersaftrek apply to a DGA?

Not to income earned through a BV structure. It applies only to genuine IB-ondernemerschap, relevant to a DGA specifically where they also run a concurrent eenmanszaak or ZZP practice alongside their BV.