As a consultant or interim manager you choose between a sole proprietorship and a bv (private limited company). With a sole proprietorship you pay income tax on the profit, with entrepreneur deductions. With a bv, the bv pays corporate income tax, and you pay yourself a salary and possibly a dividend.
You do not choose that salary freely. The law sets a customary salary: at least € 58,000 in 2026, and more if someone in employment doing comparable work earns more. With a consultant almost all turnover comes from their own work. That is why the tax authority looks closely at this salary for consultants in particular, also when it runs through a holding.
In short
- With a bv you pay yourself at least the highest of three amounts: the pay for comparable work, the pay of your best-paid employee and € 58,000 (2026). Lower is only possible if you show that comparable work pays less.
- A management fee that your holding invoices to the operating bv does not lower the customary salary. The tax authority sets the salary at the holding or across the whole group (knowledge group positions KG:204:2026:12 and 13).
- Proposals are ready for 2027: a lower self-employed deduction (€ 900) and a lower top rate in box 2 (29.2%). That is only certain once parliament agrees. The customary salary for 2027 follows in December.
In this article
- What is the difference between a sole proprietorship and a bv for a consultant?
- How much salary must you pay yourself from your bv?
- Why can the customary salary for a consultant be higher than € 58,000?
- Does a management fee through your holding lower the customary salary?
- Can you invoice your own bv as a freelancer?
- Does a bv protect you against false self-employment and claims?
- What changes in 2027?
What is the difference between a sole proprietorship and a bv for a consultant?
With a sole proprietorship the profit counts as income in box 1. In 2026 you get a self-employed deduction of € 1,200 if you meet the hours criterion (Belastingdienst, self-employed deduction 2026). The hours criterion means that you work at least 1,225 hours a year on your business, and more than on other work, such as a job (Belastingdienst, hours criterion).
After that, 12.7% of the profit is deducted as the SME profit exemption. No hours criterion applies to it (Belastingdienst, SME profit exemption).
With a bv, the bv pays corporate income tax: 19% on profit up to and including € 200,000 and 25.8% above that (Belastingdienst, corporate income tax rates). You are then a director and major shareholder (dga): you work for the bv and hold at least 5% of the shares. You receive a salary from the bv. If the bv pays a dividend, you pay box 2 tax in 2026: 24.5% up to € 68,843 and 31% above that (Belastingdienst, box 2).
At what profit a bv becomes more favourable and how you convert is covered in the article converting a sole proprietorship into a bv. Below we look at what is different for a consultant: the salary you pay yourself.
How much salary must you pay yourself from your bv?
At least the highest of three amounts. The law names the pay in the most comparable employment, the highest pay of the employees in the bv or a related company, and a fixed amount of € 58,000 in 2026 (art. 12a(1) Wage Tax Act 1964). This is called the customary salary (gebruikelijk loon).
Lower is only allowed if you make it plausible that the most comparable job pays less (Belastingdienst, salary and substantial interest). The comparison is then with employees in an ordinary job, with no shareholder involved. If the salary for all your work in the bv and related companies together is no more than € 5,000, the rule does not apply (art. 12a(4)).
Many owner-directors choose exactly the fixed amount. Research on Dutch tax records for 2007 to 2011 shows that the salary of owners of small companies peaks sharply at the minimum of the rule (Bettendorf, Lejour and Van 't Riet, 2017). Why that is so is explained in why so many owner-directors choose exactly the lowest salary.
Why can the customary salary for a consultant be higher than € 58,000?
Because the pay for comparable work can be higher. The fixed amount is only a floor. If an employed consultant doing the same work earns more, that higher pay applies. If the inspector wants to argue this, they must show you on which points they consider that job comparable (art. 12a(6)).
CBS (Statistics Netherlands) measures the gross hourly pay of business and organisation consultants in employment. In 2025 the median was € 38.70 and the 75th percentile € 48.50, excluding holiday pay, bonus and overtime (CBS, table 86355NED). For a full working week of 40 hours, as a worked example 2,080 hours a year, that is about € 80,500 and € 100,900 a year. That is not a standard, but it shows that the fixed amount can be low for an experienced consultant.
Sometimes the inspector works back from the turnover: what the bv earns from your work, minus costs and a reasonable profit. This is called the skimming method (afroommethode). In 2016 the Supreme Court decided that the inspector may not use that method if a comparison with an ordinary job is possible (Supreme Court 24 June 2016, ECLI:NL:HR:2016:1269). Back in 2004 the Supreme Court ruled that the inspector must provide data showing which salary is customary (Supreme Court 17 September 2004, ECLI:NL:HR:2004:AN8666).
So record yourself how you arrive at your salary: how many hours you work, what kind of work it is, and which vacancies or salary data you compared. You need that evidence if you want to go below the other amounts.
Does a management fee through your holding lower the customary salary?
No. Many consultants work with a holding that invoices a management fee to the operating bv or to the client. The tax authority still sets the customary salary with the rule in art. 12a. That is stated in two positions of the payroll tax knowledge group from July 2026. A knowledge group is a group of specialists within the tax authority that decides how inspectors apply a rule.
- Do you really work only for your holding, and is the engagement between the holding and the operating bv genuine? Then the rule applies at the holding. The salary you receive is the starting point, even if it is € 0, and the inspector determines the customary salary. In doing so they may compare with the employees of the operating bv (KG:204:2026:12, 15 July 2026).
- Is the engagement not genuine, and do you actually work as an employee for the operating bv? Then the tax authority applies the on-paid wage scheme (doorbetaaldloonregeling) and the rule covers your work across the whole group. About the fee the position says there is no direct link between these amounts (KG:204:2026:13, 20 July 2026).
So the fee is not a way to make your salary lower. It only moves the place where the salary is set. A fee can have other reasons, such as separating risks or keeping profit in the holding.
Can you invoice your own bv as a freelancer?
Usually not as a business. In a case at the Arnhem-Leeuwarden Court of Appeal an owner-director invoiced a management fee of € 65,000 from a sole proprietorship to a bv in which he held a substantial interest. There were no other clients and no other activities. The court ruled that there was no business, and that the fee was salary from a deemed employment (Arnhem-Leeuwarden Court of Appeal 28 October 2025, ECLI:NL:GHARL:2025:6762).
The result: no self-employed deduction and no SME profit exemption on that fee. Anyone who works for a bv in which they hold a substantial interest falls under wage tax, and then the customary salary rule applies too.
Does a bv protect you against false self-employment and claims?
Not against false self-employment. The government writes that the legal form in itself does not prevent false self-employment. What matters is how the work is done in practice (Government of the Netherlands, FAQ on false self-employment). An interim manager who works in the line of an organisation through their own bv may therefore still turn out to be working as an employee.
A bv protects you partly against claims. The client makes the contract with the bv, and the bv is liable for a mistake. If the client gave the engagement with you as a person in mind, you must do the work yourself, and the bv remains liable (art. 7:404 Dutch Civil Code). In addition, an injured party can in certain cases hold you personally liable, for example on the basis of a tort (art. 6:162 Dutch Civil Code). A bv therefore does not replace good terms and conditions or professional liability insurance.
What changes in 2027?
That is not yet fixed. The proposals for 2027 only become law once the House of Representatives and the Senate adopt them. The House of Representatives votes on the Tax Plan 2027 on 12 November 2026. The government publishes the customary salary for 2027 in December.
| Item | 2026 (law) | 2027 (proposal) |
|---|---|---|
| Self-employed deduction | € 1,200 | € 900 |
| Start-up deduction | € 2,123 | € 10 |
| Box 2, top rate | 31% | 29.2% (government plan) |
| Customary salary | € 58,000 | follows in December |
The lower self-employed deduction and start-up deduction are in the Tax Plan 2027 (KVK, tax plans 2027 for sole proprietorships). The lower 29.2% rate in box 2 is a government plan of 29 September 2026, for 2027 to 2030 (Accountancy Vanmorgen, 29 September 2026). If it goes ahead, dividends from the bv become slightly cheaper and the sole proprietorship slightly less favourable. Only work out your choice definitively once the law is in place.
Sources
- Wage Tax Act 1964 (Wet op de loonbelasting 1964), article 12a, version 1 January 2026. wetten.overheid.nl
- Belastingdienst, Salary and substantial interest (in Dutch), accessed 31 October 2026. belastingdienst.nl
- Payroll tax knowledge group, KG:204:2026:12, On-paid wage scheme with a genuine contract for services (in Dutch), 15 July 2026. kennisgroepen.belastingdienst.nl
- Payroll tax knowledge group, KG:204:2026:13, Customary salary with a non-genuine contract for services under the on-paid wage scheme (in Dutch), 20 July 2026. kennisgroepen.belastingdienst.nl
- Supreme Court of the Netherlands 24 June 2016, ECLI:NL:HR:2016:1269. uitspraken.rechtspraak.nl
- Supreme Court of the Netherlands 17 September 2004, ECLI:NL:HR:2004:AN8666. uitspraken.rechtspraak.nl
- Arnhem-Leeuwarden Court of Appeal 28 October 2025, ECLI:NL:GHARL:2025:6762. uitspraken.rechtspraak.nl
- Belastingdienst, Self-employed deduction 2026, Hours criterion, SME profit exemption, Corporate income tax rates and Box 2 (in Dutch), accessed 31 October 2026. belastingdienst.nl
- CBS (Statistics Netherlands), Employees, hourly pay and occupation, table 86355NED, year 2025, updated 30 October 2026. cbs.nl
- Government of the Netherlands, FAQ on false self-employment (in Dutch), accessed 31 October 2026. rijksoverheid.nl
- Dutch Civil Code Book 7, article 404. wetten.overheid.nl
- KVK, Tax plans 2027 for sole proprietorships and partnerships (in Dutch), accessed 31 October 2026. kvk.nl
- Accountancy Vanmorgen, Government wants to lower the excessive borrowing limit to € 100,000 and the top box 2 rate to 29.2 percent (in Dutch), 29 September 2026. accountancyvanmorgen.nl
- Bettendorf, L., Lejour, A. & van 't Riet, M. (2017). Tax bunching by owners of small corporations. De Economist, 165(4), 411-438. doi.org