Many owner-directors choose exactly the lowest salary the rules allow, because salary can be taxed more heavily than profit that stays in the company. An owner-director (dga in Dutch) owns a private limited company and is also employed by it. The law requires him to take a customary salary, in principle at least €58,000 in 2026. Dutch tax data show a clear spike around that limit. Economists call this bunching: many people choose exactly the amount at which the rules change.
In short
- In 2026 the customary salary is the highest of three amounts: the salary for comparable work, the salary of your best-paid employee and €58,000.
- An evaluation for the Ministry of Finance found spikes in 2023 around the then floor of €51,000. About 40% of owner-directors were below it.
- A low salary is not a free pass. You must be able to justify a lower salary, and the tax authority can correct it.
In this article
- Why do so many owner-directors choose exactly the minimum?
- How high must an owner-director's customary salary be in 2026?
- What do the figures on owner-director salaries show?
- Why is a low salary attractive for tax purposes?
- Do business owners in other countries do the same?
- What risks do you run if you choose exactly the minimum?
Why do so many owner-directors choose exactly the minimum?
Because every euro of salary above the minimum is often taxed more heavily than a euro of profit that stays in the company. On top of that, it is hard to determine exactly which salary fits your work. The minimum is then a safe and cheap point of reference.
An evaluation commissioned by the Ministry of Finance gives three explanations. The comparable salary is hard to establish, because there is no database of comparable jobs. Owner-directors and advisers do not experience strict enforcement by the tax authority. And some owner-directors deliberately set their salary low because of the tax advantages (SEO Economisch Onderzoek, 2025).
How high must an owner-director's customary salary be in 2026?
The customary salary is the highest of three amounts. These are the salary for the most comparable job, the salary of the best-paid employee in your company or a related company, and €58,000 in 2026. In 2024 and 2025 that last limit was €56,000 (Belastingdienst, salary and substantial interest).
A lower salary is allowed, but only if you can show that people in the most comparable job earn less. Your ownership must play no part in that comparison. If the customary salary for all your work together is demonstrably €5,000 or less, you report the salary you actually received (Belastingdienst, salary and substantial interest).
What do the figures on owner-director salaries show?
They show a clear spike around the statutory floor. In 2023, when that limit was €51,000, a strikingly large share of customary salaries was around that amount. About 40% were even below it (SEO Economisch Onderzoek, 2025).
The evaluation used Statistics Netherlands (CBS) microdata on 359,062 customary salaries in 2023. Of the owner-directors below the limit, almost ninety percent are start-ups or work part-time. That can justify a lower salary, but the researchers doubt whether it explains everything, because owner-directors do not have to record their hours precisely (SEO Economisch Onderzoek, 2025).
The pattern is not new. A peer-reviewed study using Dutch tax data from 2007 to 2011 already found that the gross salary of owners of small companies is heavily concentrated at the minimum reference salary in the law. Taxable salary also clusters at the limits of the tax brackets (Bettendorf, Lejour & Van 't Riet, 2017).
According to the evaluation, the rule still achieves most of its aim. Owner-directors' total salaries are about eighty percent of what they would be if everyone took the right salary. The rule raises an estimated 0.9 to 2.3 billion euros in tax and contributions (SEO Economisch Onderzoek, 2025).
Why is a low salary attractive for tax purposes?
Because salary in box 1 is taxed more heavily at higher incomes than profit in the company. On salary above €78,426 you pay 49.50% income tax in 2026. Profit in the company first costs 19% corporate tax up to €200,000, and box 2 only follows when it is paid out.
Box 1 is the tax on income from work, box 2 the tax on income from a substantial interest, such as dividend from your own company. In 2026, box 1 has three rates for people below state pension age: 35.75%, 37.56% and 49.50% (Belastingdienst, box 1). Corporate tax is 19% on profit up to and including €200,000 and 25.8% above that (Belastingdienst, corporate tax rates). In box 2 you pay 24.5% up to €68,843 and 31% above that (Belastingdienst, box 2).
The worked example shows the difference. On an extra euro of salary in the top bracket you pay almost 50 cents. If that same euro goes to the company as profit and later to you as dividend, the total is about 39 cents. If you leave the profit in the company, you only pay the 19 cents of corporate tax for the time being.
That deferral may be the most important incentive. Bettendorf and colleagues found that Dutch owners strongly adjusted their profit distributions to a temporary cut in the dividend rate in 2007, from 25% to 22%. Dividend tax revenue then doubled. According to the researchers, shifting income over time remains important for business owners (Bettendorf, Lejour & Van 't Riet, 2017).
Do business owners in other countries do the same?
Yes. Where business owners can set their own income, they often choose exactly the amount where a more favourable rule begins or ends. Employees on a fixed salary hardly do this, because they do not have that choice.
In the United States, Saez found clear bunching at the first kink of a tax credit for working people, but only among the self-employed. At most other thresholds in the rate schedule he saw no bunching (Saez, 2010). So the difference lies in who can steer their income.
Danish self-employed people cluster at the limit of the top rate. More than half of that bunching came from them leaving profit in their business and shifting income to later. Anyone who ignores this overestimates how strongly income really responds to higher rates (le Maire & Schjerning, 2013). A review shows that this kind of clustering at thresholds occurs in many countries and schemes (Kleven, 2016).
What risks do you run if you choose exactly the minimum?
The minimum is only safe if your work is not worth more. The law looks first at the salary for comparable work and at your best-paid employee. If either of those is higher than €58,000, the minimum is too low.
Using a wage comparison, the evaluation estimates that owner-directors with a salary up to about €70,000 on average pay themselves less than comparable employees earn (SEO Economisch Onderzoek, 2025). Anyone who takes a lower salary must be able to justify it if the tax authority asks. You do not have to report it in advance, but the burden of proof is on you.
Also watch the former limit. Until 2023, the customary salary could be up to 25% lower than the comparable salary. That margin has been abolished, but the evaluation saw hardly any salary increases afterwards (SEO Economisch Onderzoek, 2025). Anyone who has not reviewed their salary since then runs a greater risk of a correction.
The key point: the spike at the minimum is a rational response to the incentives in the system. The minimum is a floor for those without a higher comparable salary, not a standard amount for everyone. A written justification is your best protection.
Sources
- SEO Economisch Onderzoek (Schwartz, T., Stabler, D., Knol, J., Ourak, W., Lejour, A. & Bijlsma, M.) (2025). Does the owner-director pull his weight? Evaluation of the customary wage rule (in Dutch). Commissioned by the Ministry of Finance, April 2025. seo.nl
- Belastingdienst. Salary and substantial interest (Loon en aanmerkelijk belang). Accessed October 2026. belastingdienst.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/10.1007/s10645-017-9303-x
- Belastingdienst. Box 1: explanation and rates 2026. Accessed October 2026. belastingdienst.nl
- Belastingdienst. Corporate tax rates 2026. Accessed October 2026. belastingdienst.nl
- Belastingdienst. Box 2: explanation and rates 2026. Accessed October 2026. belastingdienst.nl
- Saez, E. (2010). Do taxpayers bunch at kink points? American Economic Journal: Economic Policy, 2(3), 180-212. doi.org/10.1257/pol.2.3.180
- le Maire, D. & Schjerning, B. (2013). Tax bunching, income shifting and self-employment. Journal of Public Economics, 107, 1-18. doi.org/10.1016/j.jpubeco.2013.08.002
- Kleven, H.J. (2016). Bunching. Annual Review of Economics, 8, 435-464. doi.org/10.1146/annurev-economics-080315-015234