Weak turnover may explain lower pay, but the payroll record must carry the story.
A small BV owner does not usually lower her own salary because she enjoys tax risk. She does it on a Thursday evening, after rent, supplier invoices, VAT, software bills, and staff wages have already taken their share of the bank balance. Her own pay is the line that can wait. The company needs stock. A debtor is late. The bank wants answers.
The signal has to become readable
That scene is common in Dutch owner-managed companies. It is also where the customary salary rule for a director-major shareholder, the DGA, becomes more than a tax paragraph. The question is not only what left the bank account. The question is what salary the BV can defend for the work done inside the company.
A 2025 Gerechtshof Den Haag case kept the focus on continuity pressure. That matters. A company under real strain may have a serious reason to pay the DGA less than the standard amount. The current policy line still points the other way, toward proof, valuation, and better application, not toward a looser rule.
Cash comes first, but payroll follows
Belastingdienst guidance says the customary salary for 2026 is normally the highest of three figures. Those figures are the wage from the most comparable employment, the wage of the highest-paid employee at the company or a connected company, or €58,000.
For 2025 and 2024, the statutory amount was €56,000.
A lower salary can still be possible. Official policy recognises lower comparable wages, structural losses, part-time work, and a starting business. These are not magic words. The burden of proof sits with the withholding agent, usually the BV. Advance agreement with the Belastingdienst is not mandatory, but the evidence must be ready when the question comes.
This is where many founders make a human mistake. They think the lower salary is obvious because the bank balance is obvious. Tax does not read stress from a bank screen. It reads payroll returns, accounts, wage comparisons, hours, duties, connected companies, and payment records.
The number is only the start
The BV is the withholding agent for payroll tax. Official policy also makes a point many owners dislike but need to understand: payroll tax can still be due on the customary salary even when the salary is not actually paid out. Leaving cash inside the company does not erase the wage question.
What the signal changes
The same policy letter that keeps the 2026 norm at €58,000 also says the regime was assessed as efficient and partly effective. The Belastingdienst will analyse available data to gain more insight into whether the regime is being applied correctly. The next step is better valuation, not a softer line.
That matters because low DGA wages are not rare. A 2025 evaluation reported about 332,000 substantial-interest holders paying themselves wages at about 359,000 companies in 2023. Around 40 percent of customary salaries were below the statutory lower limit.
Some of those positions will be fully defensible. Some will be thin. The difference is usually in the file. The payroll return, salary accrual, current-account entries, bank payments, and board or shareholder notes should tell one story.
What the ledger has to say
Take the small online wholesaler again. The founder works real hours, buys inventory, handles customer problems, and negotiates with suppliers. One employee earns a regular wage. Sales are weak, stock still has to be financed, and debtor payments are slow. The founder reduces her own salary to keep the company moving.
That can be commercially understandable. It is not yet a payroll tax explanation. The ledger should show why the cash had to stay in the business, how long the pressure lasted, what work the DGA performed, and why the salary fits the role. A senior employee or a connected BV can sharpen the comparison further.
I would also look for consistency. When one file says the company is under pressure and another file says nothing changed, the lower salary position weakens fast. A bookkeeping trail that looks improvised rarely helps later.
Market pressure does not replace proof
The business climate gives founders a reason to be careful. CBS reported business confidence of -14.8 at the start of the second quarter of 2026. That was the largest fall since early 2022 and the lowest level since the end of 2022.
CBS also reported that CAO wages per hour, including special payments, were 4.5 percent higher in the first quarter of 2026 than a year earlier. For private companies, the rise was 4.9 percent.
What founders should check
DNB reported that SMEs paid about 3.6 percent on outstanding bank credit in March 2026, compared with about 3.1 percent for non-SMEs. So the owner of a small BV may face a hard combination: customers resist price increases, staff wages move, suppliers press, credit costs money, and the owner’s own pay becomes the shock absorber.
These numbers explain pressure. The ledger still has to justify the salary.
Keep salary and payment trouble apart
There is another trap. A defensible lower salary and an inability to pay payroll tax or VAT are different problems. The Belastingdienst payment-inability rules have their own timing. For tax due on return, the report must be sent within two weeks after the tax should have been paid.
A late or incomplete report is legally ineffective and can expose the director to liability for unpaid tax debt. The report is not a request for deferral or remission.
That sounds technical, but the business meaning is simple. Do not let one cash problem become three files with blurred edges. Salary level, payroll tax return, and payment inability each need their own clean record.
Back at the Thursday evening bank screen, the founder may still decide that her own salary has to come down. Sometimes that is the adult decision. But it still needs paperwork behind it. Hours, duties, comparable pay, losses, stock needs, liquidity forecasts, connected companies, and tax payments belong in the same conversation.
A low DGA salary is not suspicious by nature. It is suspicious when it has no spine. In a weak year, the BV may need every euro inside the business. The payroll file then has to show why that was true, and why the owner’s labour was valued as it was.
Cash survival can be real. Tax trust is built in the records. If the company cannot carry the normal salary, let the accounts show the reason before someone else has to ask.
Sources
Referenced in the article
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