Owner-director? You are probably at risk with the Tax Authority.

As a director-shareholder (DGA), you are both entrepreneur and employee simultaneously. That gives you freedom — but also responsibilities that many DGAs underestimate.

The Dutch Tax Authority looks critically at DGA structures. And rightly so — this is where the biggest risks of back taxes, fines and unwelcome attention lie.

These are the three areas where things most often go wrong.

1. Customary salary (gebruikelijk loon)

You are required to pay yourself a market-rate salary. The minimum for 2025 is €56,000. Pay yourself less — without solid substantiation — and you risk a correction and a penalty.

What many DGAs do not know: the Tax Authority may use the highest of three amounts. That is almost always higher than what you are paying yourself.

2. Shareholder loan (rekening-courant)

Borrowing from your own BV is tempting. But a growing shareholder loan is one of the most common red flags in a tax audit.

Since 2023 the Excessive Borrowing Act applies: borrow more than €700,000 from your BV and the excess is taxed as income. No deferral, no escape.

3. Dividend without a solvency test

Paying a dividend is permitted — but only if the BV can sustain it. Directors are personally liable if a distribution threatens the continuity of the company.

Many DGAs pay dividends based on gut feeling, not on a formal test. That is an avoidable risk.

Recognise any of these? Time for a tax conversation.

Frank Verhoeven is tax lawyer at Futura Accountancy and spent many years at the Dutch Tax Authority. He knows how they think — and how to prevent risks before they arise.