This article explains the tax differences between investing within the BV and transferring assets to private ownership. We assume a fiscally claimed profit reserve in the BV, and that there are no fiscally compensable losses.
"}},{"componentType":"sectionTitle","title":"How tax on returns works within the BV"},{"componentType":"paragraph","richBody":{"value":"As soon as you generate returns within the BV, you pay corporate income tax on the result. If you receive savings interest or dividends (not covered by the participation exemption), these are taxed immediately. Capital gains can be deferred under certain conditions. For example, you can value participations in certain investment funds at cost or lower market value. But this is not always possible: it depends on the type of investment and the structure of the fund. Consult your asset manager and tax advisor about this.
In 2026, the corporate tax rate stands at 19% on profits up to €200,000, and 25.8% on amounts above that threshold. Should you choose to distribute net profits to yourself, the proceeds are taxed under Box 2 of the Dutch income tax regime. This entails a two-tiered structure: 24.5% on income up to €68,843 and 31% above that. For those with a fiscal partner, the threshold doubles to €137,686. Any withheld dividend tax may be offset against the Box 2 tax.
"}},{"componentType":"sectionTitle","title":"When should you transfer to private ownership?"},{"componentType":"paragraph","richBody":{"value":"Wondering whether it’s smart to move your BV’s investment funds to your personal assets? Compare the tax burden within the BV to that in Box 3.
There are tipping points in 2026:
Only when you expect to exceed these returns is it more attractive to distribute to private ownership. Yet, many factors can influence these tipping points. What is your investment horizon? How do you value the investments? For example, are you deferring capital gains in the BV? Also note that losses in the BV may be tax-deductible (under specific conditions), which is not possible in Box 3.
"}},{"componentType":"sectionTitle","title":"Alternatives and considerations"},{"componentType":"paragraph","richBody":{"value":"In practice, many directors-major shareholders (DGAs) borrow money from their BV to defer taxation. But be careful: the loan must be businesslike and actually repayable, or you risk taxation as disguised profit distribution (Box 2). Also consider the Excessive Borrowing Act: if you (alone or with your fiscal partner) borrow more than €500,000 from your BV, the excess is taxed in Box 2. Mortgage debts for your own home are exempt under certain conditions.
Finally, besides tax aspects, other factors also play a role, such as your pension provision in the BV, potential liability claims, and the annual maintenance costs of your BV.
"}},{"componentType":"sectionTitle","title":"Make the right choice and get advice"},{"componentType":"paragraph","richBody":{"value":"Your situation is unique. Want to know what’s best for you? Ask your tax advisor for guidance. The experts at ING Private Banking are there to help you structure your investments, whether in your BV or privately. Contact us for personalized advice tailored to your goals and wishes.
"}},{"componentType":"accordion","accordionList":[{"title":"Based on the situation as of 24 April 2026","richBody":{"value":"The information provided by ING in this article is not an offer, advice, or financial service and is intended solely to inform and provide practical tips. We always recommend consulting a specialist for your financial and/or wealth planning. This article has been compiled with the utmost care. However, it may contain inaccuracies or omissions. ING is not liable for any damage (of any kind) resulting from the use of the provided information. No rights can be derived from the information. Any mentioned rates are indicative and not binding for ING. All rights and changes reserved. This is a publication of ING Bank NV, registered in Amsterdam.
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