What the cabinet has announced
In its letter to Parliament of 29 September 2026, the cabinet proposes reducing the borrowing threshold in five annual steps of €80,000 from 2027. It also proposes setting the second-bracket box 2 rate at 29.2% for four years from 2027. These proposals form part of the financing for changes to box 3, the Dutch regime for income from savings and investments. The €100,000 threshold would therefore not apply immediately from 2027.
Start with the existing rules
For 2026, the basic excessive borrowing threshold is €500,000. Relevant debts that you and your tax partner owe to your own companies are assessed together. Previous taxation of excessive debt may affect your personal threshold. A loan for your main residence may be excluded if the applicable conditions are met. Establish which debts count before applying an announced reduction to your total financing.
A tax charge does not repay the loan
A box 2 charge on excessive debt does not make that debt disappear. Interest and repayment arrangements remain relevant. A dividend distribution is also different from repayment: the corporate decision, tax treatment and actual payment must be consistent. A loan-by-loan overview shows how the money was used and which obligations remain with the DGA and the BV. Box 2 concerns Dutch income from a substantial shareholding; it is not a separate loan repayment mechanism.
The proposals are still being developed
The letter to Parliament of 9 October states that the amendment to the box 3 bill is before the Council of State for advice. The cabinet also indicates that it intends to adjust the financing before submitting the amendment. The September plans therefore do not provide a definitive basis for a repayment or dividend decision. Allow for changes to the amounts, conditions and commencement dates in your preparations.
Assess your financial capacity in advance
Useful preparation begins with debt balances, loan agreements, security and expected liquidity. What repayments can you afford personally? How much can the BV release while retaining funds for its activities? Consider these questions alongside the current tax rules and the interests of the business.
Develop several scenarios and record their assumptions. This allows you to adjust decisions when the legislation becomes clearer without rebuilding your planning each time. A concrete debt overview is more valuable than a decision based solely on a proposed tax rate.
More information from Oudshoorn
Sources and background
Original source publication: — Fiscaal Vanmorgen on excessive borrowing and box 2.
