The €58,000 question keeps Dutch entrepreneurs awake at night. You’ve incorporated your BV (private limited company), you’re pulling in solid revenue as a freelance marketer or consultant, and your accountant delivers the good news: just pay yourself the minimum DGA (director-major shareholder) salary of €58,000 and keep the rest in the company. More money for investments, less tax now. Seems straightforward.
Then you check market rates for your role. That same work as an employee would easily command €70,000, maybe €80,000 or more. Your friend’s accountant told her to benchmark against three job vacancies and set her salary at €85,000. Suddenly that €58,000 feels less like a smart tax move and more like a flashing red target on your back.
This is where the Dutch tax system stops being a predictable machine and starts feeling like a calculated gamble.
What “Gebruikelijk Loon” Actually Means
The law sounds simple. A DGA must pay themselves a salary that’s “customary” for their role. The Belastingdienst (Tax Authority) gives you three tests, and you must pick the highest number:
- 100% of the salary from the most comparable employment, what would you earn doing this job for someone else?
- The salary of your highest-paid employee, if you have staff, you can’t undercut them
- The statutory minimum, €58,000 in 2026
The catch? Most accountants skip straight to option three. It’s clean, defensible, and matches the “normbedrag” (standard amount) that gets indexed annually. But the law explicitly requires you to consider option one first. If your comparable salary is €75,000, that’s what you should technically pay yourself.
The distinction matters because of the burden of proof. If you pay yourself less than €58,000, you must prove it’s justified. Between €58,000 and the market rate, the Belastingdienst must prove it’s too low. At exactly €58,000, many assume they’re safe. They’re not entirely wrong, but they’re not entirely right either.
When the Tax Inspector Comes Knocking
Here’s what actually happens during an audit. One DGA who was inspected shared his experience: he paid himself €64,000 while his holding company turned over €300,000 with additional dividend streams. The inspector opened the conversation about his salary justification. He produced a handful of recent job postings from companies known for paying below-market rates. That was enough. The case closed in his favor.
The key insight from his story isn’t that you can get away with lowballing. It’s that the Belastingdienst applies a reasonableness test, not a maximum enforcement approach. They’re looking for clear abuse, not technical violations. Paying €58,000 for a role that demonstrably pays €90,000 elsewhere? That’s a risk. Paying €58,000 when you can show some comparable positions at €60,000-65,000? You’re likely fine.
But this reasonableness cuts both ways. Another entrepreneur noted that once your salary drops below the €58,000 threshold, the scrutiny intensifies. The tax office knows that’s where the real tax games happen, and they’ll demand rock-solid justification. Staying at the minimum actually puts you in the least questioned zone, even if it’s not strictly market-conform.
The Market Rate Problem for Digital Professionals
The dilemma is particularly sharp for online marketers, developers, and consultants. Research from Emerce shows median salaries for experienced digital professionals comfortably exceed €70,000, with many roles pushing past €80,000. If you’re a freelance online marketer with ten years of experience, your comparable employment salary isn’t €58,000, it’s likely €75,000+.
Yet your accountant isn’t wrong about the tax math. The difference between €58,000 and €75,000 in salary is roughly €8,000 more in income tax and social premiums (box 1). If you leave that €17,000 in the company, it gets taxed at 19% corporate tax (VPB), and you can defer paying the 24.5% dividend tax (box 2) until you actually need the money. The time value of that deferral can be substantial, especially with the upcoming 2028 Box 3 tax changes affecting BV formation decisions.
The tension is clear: tax optimization pushes you toward €58,000. Market reality and audit risk push you higher. Most accountants advise clients to take the risk, citing low audit probability. But “low probability” isn’t “no probability”, and the penalties for getting caught include back taxes, interest, and potentially a 100% penalty on the avoided tax.
Calculating Your Personal Risk Threshold
Let’s run the numbers on a realistic scenario. You’re a marketing consultant with a €180,000 annual profit in your BV.
Option 1: Minimum Salary (€58,000)
– Personal income tax: ~€18,000
– Social premiums: ~€3,500
– Net take-home: €36,500
– Remaining profit: €122,000
– Corporate tax (19%): €23,180
– Available for dividends: €98,820
– Deferred dividend tax (24.5%): €24,211 (paid later)
Option 2: Market Salary (€75,000)
– Personal income tax: ~€26,000
– Social premiums: ~€4,800
– Net take-home: €44,200
– Remaining profit: €105,000
– Corporate tax (19%): €19,950
– Available for dividends: €85,050
– Deferred dividend tax (24.5%): €20,837 (paid later)
The immediate tax saving by staying at €58,000? About €8,000 in box 1 tax now, plus slightly more retained earnings. The risk? If the Belastingdienst successfully reclassifies €17,000 of dividends as salary, you’d owe that €8,000 in back taxes, plus interest (currently around 4% annually), plus a penalty that could double the amount.
Documentation Strategies That Actually Work
The entrepreneurs who survive audits share a common approach: they build a justification file before any questions arise. This isn’t just collecting three low-paying job ads. It’s a structured argument that includes:
- Scope of work: Document that you’re only doing execution, not full management responsibilities
- Part-time hours: If applicable, show you work fewer hours than a full-time employee
- Business risk: Demonstrate your income fluctuates more than salaried staff
- Industry benchmarks: Use salary surveys showing wide ranges, not just median figures
- Company size: Smaller BVs legitimately pay less than large corporations
One DGA who successfully defended his €58,000 salary emphasized that he only needed to show “a number of recent vacancies from employers that pay little.” He didn’t need to prove €58,000 was market average, just that it wasn’t absurdly low. The Belastingdienst must provide counter-evidence, and they rarely do unless your case is extreme.
However, this defense weakens as your BV grows. If you have employees earning €70,000, or your revenue hits seven figures, paying yourself €58,000 looks increasingly artificial. The tax office knows this, and they’ll adjust their scrutiny accordingly.
The Bigger Picture: Box 3 and the BV Advantage
The DGA salary question doesn’t exist in isolation. It’s part of a broader strategy around wealth accumulation and the impact of 2028 Box 3 reforms on investment taxation and financial planning. Money retained in your BV avoids Box 3 wealth tax until distributed. For entrepreneurs building significant capital, this deferral is worth more than the salary tax savings.
This is why many DGAs accept the audit risk. They’re playing a longer game where retaining €100,000+ annually in the company creates a tax-deferred investment vehicle. The €8,000 annual risk is a calculated cost of doing business, like insurance.
But the rules are tightening. The 2028 Box 3 overhaul has Dutch families already restructuring their holdings, and the Belastingdienst is increasingly sophisticated in tracking DGA behavior. What worked five years ago might not work in 2026.
When to Stop Playing the Game
There’s a point where the risk-reward flips. If your comparable salary is €95,000 or higher, paying €58,000 becomes hard to defend. The gap is too wide. Many accountants then recommend a split strategy:
- Pay yourself €65,000-70,000 (still below market but more defensible)
- Contribute the excess to a lijfrente (annuity) or pension scheme
- This avoids Box 3 while building a justification file
One commenter suggested: “Do a slightly higher DGA salary and put that money into a pension. You don’t pay Box 3 or income tax on it, but you still have a market-conform salary.” This approach costs you social premiums now but eliminates audit risk while preserving tax deferral.
The breakpoint varies by industry. For senior developers or specialized consultants where market rates exceed €90,000, even €70,000 looks suspicious. For creative professionals or early-stage entrepreneurs with volatile income, €58,000 is easier to justify.
The Bottom Line: Know Your Number
The €58,000 minimum isn’t a safe harbor. It’s a rebuttable presumption that shifts the burden of proof to the tax office. That presumption holds only as long as it’s not obviously contradicted by market data.
Your decision should rest on three factors:
- Audit probability: Higher revenue, employees, or consistent high profits increase your chance of selection
- Market gap: The wider the spread between €58k and your true market rate, the weaker your position
- Documentation quality: Can you produce a contemporaneous file showing reasonable justification?
Most DGAs in the €70,000-80,000 market range can safely stay at €58,000 with decent documentation. Those in the €90,000+ range should consider €65,000-70,000 as a minimum. Those below €70,000 market rate can sleep easy at €58,000.
The real mistake isn’t paying €58,000. It’s paying €58,000 while having no documentation, clearly marketable skills worth double, and a growing, stable BV that looks like an employment vehicle rather than a risky startup. The Belastingdienst isn’t hunting small fish. They’re hunting artificial structures.
So how low can you go? As low as €58,000. But only if you’re prepared to defend it like a thesis. Otherwise, that “tax saving” might be the most expensive money you never spent.
