Director-shareholder current account 2026
Almost every director-major shareholder (DGA) has a current account with their own private limited company (BV), and yet the subject remains shrouded in uncertainty for many entrepreneurs. When are you allowed to withdraw money from your BV? What interest rate should you charge? When does the Tax and Customs Administration step in?
Here you can read exactly what a DGA current account is, how it arises, which tax rules apply in 2026 and how to avoid tax surprises, including both sides of the current account relationship.
What is a director’s current account?
A DGA current account is an ongoing internal record of money flows between you, as the director-shareholder, and your BV’s business bank account. This current account keeps track of all amounts moving back and forth between you personally and your company, without the need to draw up a separate loan agreement each time. The balance can be either a debt or a receivable, depending on the direction in which the money flows.
A current account is not an ordinary loan
Although a current account functions as a kind of loan between you and your BV, it differs in important respects from a standard loan: the balance is dynamic, there is no fixed final amount and no strict repayment schedule. That flexibility is what makes current account attractive, but also risky.
The tax conditions that apply to a standard loan continue to apply in full. You need a written agreement, a commercial interest rate, clear arrangements on security and a reasonable relationship to the debtor’s ability to repay; otherwise the tax authorities may reclassify your current account as a distribution or disguised salary.
Why almost every DGA has a current account with their BV
In day-to-day practice, money is constantly moving between you personally and your BV. You pay for a business purchase with your personal card, the BV pays for a subscription that is also used privately, or you take an advance on your salary.
Without a current account, you would have to set up a separate transaction or loan agreement for every amount; that is not workable for most DGAs. The current account therefore serves as an internal clearing account in which all mutual positions between you and your BV are recorded when using multiple business accounts.
How does a current account arise between a director-major shareholder and a private limited company?
A current account relationship rarely arises from a deliberate decision. The balance usually grows gradually through small cash flows that follow one another. Below you can see the most common scenarios in which a current account between a DGA and a BV arises or increases.
Business expense on your private card: you pay business expenses, a business lunch or a software subscription with your private card. Until the BV pays you back, the BV owes you a debt in current account.
Private purchase on your business card: you pay for private groceries with your business card or book a private trip via the business account. That gives rise to a claim by the BV on you.
Salary or dividend not yet paid out: your DGA salary or a declared dividend distribution remains on paper but has not yet been transferred. That unpaid amount is entered in current account as a debt of the BV to you.
Advances of costs or capital contributions: you inject private money into the BV to cover a temporary liquidity dip, or you advance money for a business investment. As long as this is not a formal capital contribution, you have a claim on the BV.
Current account debt between the director-major shareholder and the private limited company
A current account relationship has two sides, and which side applies in your situation makes a big difference for tax purposes. In one case, as a DGA you owe the BV something, in the other the BV owes you something.
Both variants occur, both have their own tax rules, and both require a written agreement and commercial terms. Below you can see what applies on each side and what the Tax and Customs Administration looks at first during an inspection.
Current account debt of the DGA to the BV
This is by far the most common variant. You build up a debt to your own BV when you regularly withdraw more money from your business account than your agreed salary, when private expenses are run through the business account, or when you use the BV as an ongoing source of finance for personal investments. Technically this is allowed, but for tax purposes it is an area that the Tax and Customs Administration watches closely.
Commercial terms must demonstrably be in place: a written agreement, an arm's-length interest rate, security and a realistic repayment schedule. If one of these elements is missing, you run the risk that the Tax and Customs Administration will not accept the debt as a loan.
Ability-to-repay test based on salary and private assets: taking your income and private assets into account, can you reasonably repay the debt over time? If not, the question arises whether repayment was ever seriously intended. For the tax authorities, that is an important signal that can lead to reclassification.
Reclassification as a distribution affects you in Box 2: if the Tax and Customs Administration concludes that the current account is in substance a disguised transfer of assets, the amount is taxed as income from a substantial shareholding at a rate that rises to 31 per cent in 2026. If there is deliberate concealment, a penalty may follow.
Signals the tax authorities look for: a debt that builds up for years without repayment, insufficient security, no or very low interest compensation, withdrawals for consumer purposes that are not proportionate to your income, and the absence of a written agreement.
Current account debt of the BV to the DGA
The reverse situation, where you as a DGA are owed something by your own BV, receives much less attention in practice. Yet this variant is at least as relevant, and for tax purposes often less favourable than many DGAs realise. A debt of the BV to you often arises gradually, through costs advanced or deferred payments, and comes with its own tax regime.
Common ways it arises: business costs you paid in advance with your private card, agreed DGA salary that has not yet been paid, a declared dividend that has remained outstanding, or private money you contributed to the BV as a loan without a formal capital contribution.
The available-for-use regime (TBS) applies: a claim you have on your own BV falls under Article 3.92 of the Dutch Income Tax Act (Wet IB). The interest compensation you receive from the BV is taxed with you in Box 1, at the progressive rate that can rise to almost 50 per cent in 2026.
Tax-wise usually less favourable than the other side: the BV can deduct the interest for corporation tax, but you pay substantial tax on it in Box 1. On balance, this variant often results in a tax loss and a high receivable on your own BV is rarely desirable.
Written documentation remains essential: for a claim on your BV, too, you must set out the terms in writing, with a commercial interest rate and clear repayment arrangements, just as in the reverse situation.
Interest on the director-shareholder current account
On a current account between a DGA and a BV, an arm’s length interest rate should in principle be charged. That is not an arbitrary requirement, but a direct consequence of the tax principle that you must deal at arm’s length with your own BV, as if you were negotiating with an independent third party. The interest must therefore be market-conform, comparable to what an external lender would charge for a loan with comparable terms, maturity and security.
In practice, most tax advisers in 2026 use a rate between 4 and 6 per cent, depending on the size of the debt, the presence of security and the current market interest rate. If you charge a clearly too low rate, the tax authorities can add the difference as an adjustment. There is one exception: as long as the balance on the current account remains below EUR 17,500 throughout the year, no interest needs to be charged.
In that case, however, the debt may not be included in Box 3. If the balance even briefly exceeds this threshold, the exemption lapses and arm’s length interest must be paid on the full balance. Where the BV owes you money, it works slightly differently: the interest received then falls under the making-available regime and is taxed in Box 1, at the progressive rate, which is often less favourable from a tax perspective.
The current account agreement for a DGA
A written current account agreement between you and your BV is not a legal requirement, but for tax purposes it is almost indispensable. During an audit, the Tax and Customs Administration checks whether the current account meets the conditions of a commercial loan, and a clear agreement is the most important piece of evidence that you have acted in a businesslike manner. In a good current account agreement for a DGA, you should in any case set out the following elements.
Parties and basis: who the creditor and debtor are, and in what capacity they are acting (DGA privately versus BV).
Credit limit: the maximum amount the current account may reach, appropriate to the debtor's capacity.
Interest rate: a commercial, market-conform rate, with a justification of why this percentage is market-conform given the circumstances.
Repayment schedule: concrete agreements on how and when the balance will be reduced, for example through periodic repayments or annual settlement with salary or dividend.
Security: any collateral such as a mortgage right on private assets or a pledge right, depending on the size of the debt.
Accounting treatment: agreements on how and by whom the current account is maintained and periodically reconciled.
A written agreement on paper is not enough; the agreements must also actually be complied with. If the agreement includes periodic repayments that never actually take place, the document loses its tax value. Consistency between what is on paper and what happens in the annual accounts is decisive for the Tax and Customs Administration.
Excessive borrowing law: maximum current account for director-shareholders
From 1 January 2023, the Excessive Borrowing from Own Company Act has been in force. This Act sets a hard limit on how much a DGA may in total borrow from their own BV. For 2026, that limit is EUR 500,000, after the original ceiling of EUR 700,000 was reduced in 2024. Anything a DGA borrows from their BV above this limit is automatically treated as a deemed distribution and taxed in Box 2 as income from a substantial interest.
In the assessment, all debts of the DGA to their BV are added together, including current account balances, standard loans and debts of connected persons such as your partner, children, grandchildren, parents and grandparents. There is one important exception to the ceiling: debts relating to an owner-occupied home that meet the tax conditions for mortgage interest relief are not counted.
For new owner-occupied home debts from 2023 onwards, additional conditions apply, such as a mortgage right in favour of the BV; existing debts from before 2023 fall under a transitional arrangement. The assessment date is 31 December, which means that temporarily repaying around year-end and borrowing again in January will not help you: the Tax and Customs Administration assesses whether such arrangements are economically genuine.
How do you settle a large current account debt?
If your current account debt to the BV is mounting, for example towards the limit set by the Excessive Borrowing Act or because the debt becomes substantively unsustainable, there are several routes to reduce it. The right choice depends on your personal circumstances, the financial position of the BV and the timeframe in which you want to reduce the debt.
Paying out dividends to repay the debt
The most commonly used route is to pay out a dividend and immediately set it off against the outstanding debt. For tax purposes, nothing changes: on the gross dividend amount you pay up to 31 per cent tax in box 2 in 2026.
For a debt of 100,000 euros you need a gross dividend of well over 133,000 euros to end up after tax. A dividend distribution is only possible if the BV has sufficient freely distributable reserves and the management has carried out a distribution test in advance; otherwise you run a personal liability risk.
Repaying from private assets or external financing
Repaying with private funds such as savings, investments or an inheritance is the cleanest option from a tax perspective, because no additional tax is due. However, your private assets decrease, which can affect your box 3 position.
Those without sufficient private funds can seek external financing, for example a mortgage loan on their own home or a personal loan. Depending on the terms, this can sometimes work out more favourably than leaving a debt with the BV, especially when the compensation to the BV is higher than the market interest rate on external financing.
Waiver: can it be tax-free?
Waiving the current account debt by the BV is, for tax purposes, unfavourable in most cases, because the waiver is treated as a distribution of profits and therefore still leads to box 2 tax.
Tax-free waiver is in principle only possible when the receivable is genuinely irrecoverable, for example due to personal bankruptcy or obvious insolvency. The Tax and Customs Administration looks at this very critically; in practice, waiver is therefore a last resort, not a tool for regular debt reduction.
Transferring assets to the BV
A fourth route is to transfer assets from private ownership to the BV in exchange for a reduction of the debt, think investments, securities or property. The transfer value is then deducted from the outstanding current account debt.
Important is that the valuation is arrived at on an arm's-length basis: too high a value means a disguised dividend distribution, too low a value and an arm's-length benefit to the BV. For larger or more complex transactions, always seek advice from a tax adviser or accountant.
How to prevent a current account from spiralling out of control
The best way to avoid tax problems with a director-shareholder current account is to make sure the balance never unintentionally builds up. That starts with a strict separation of cash flows: business expenses on the business account, private expenses on the private account. A consistently used business payment card prevents you from paying for business purchases on your private card out of habit, or vice versa. This not only saves you from tax discussions afterwards, but also hours of administration for you and your bookkeeper.
At GoDutch, you structure your finances as a director-shareholder clearly, with a separate business account for your holding company and for each operating company, plus extra Mastercards for you and team members, so expenses end up directly on the correct account.
Thanks to the real-time overview in the GoDutch app, you can see at any moment what is in each business account, without switching between different portals. Combined with automatic recurring payments, direct access for your bookkeeper or accountant, and incoming invoices that are processed automatically, you minimise the chance of amounts getting stuck and prevent small administrative backlogs from turning into tax headaches.
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