Prinsjesdag 2024: new tax plans that affect bvs in the Netherlands

Business gift tax deduction for bv's abolished

The tax deduction for business gifts will disappear from 1 January 2025. This means that you can no longer deduct donations to 2 types of charitable institutions: Algemeen Nut Beogende Instellingen (ANBIs) and Sociaal Belang Behartigende Instellingen (SBBIs) from your profits. A business gift to an ANBI or SBBI in 2024 is still deductible.  

The maximum gift deduction per year is 50% of the profit up to a maximum of €100,000. Due to the proposed change in the law from 1 January 2025, it may be a good idea to consider making a donation to an ANBI or SBBI this year 

 If a bv makes a donation at the request of a shareholder, this is not considered a deductible gift for tax purposes, but a dividend distribution to that shareholder. The bv must withhold dividend tax on this amount. The shareholder must then also pay income tax on this in Box 2.  

Changes to the Business succession scheme

Do you inherit or are you given a business? Then you pay inheritance or gift tax. How much tax you pay depends on the value of the business. You can use an exemption: the Business Succession Scheme (BOR).  

You can use the BOR if you meet three conditions:  

• The business must be active, not just making investments. 
• The previous owner must have been an owner for at least 5 years before making the gift. If you inherit the business, this is 1 year. This is called the ownership requirement. 
• You must continue the business for at least 5 years after taking it over. You are also not allowed to sell the shares during that period. 

Do you meet these requirements? Then you can make use of the BOR. That means you get an exemption of 100% if the value of the company is €1,325,253 or less. Is the company worth more? Then you get an 83% exemption for the value above that amount.  

On Budget Day, the government proposed reducing the continuation requirement from 5 to 3 years in 2025. This will, among other things, allow you to sell your business as early as 3 years after the gift or inheritance. 

A number of other changes to the BOR are expected in 2026. 

Corporate income tax remains the same

Corporate income tax (vpb) rates remain unchanged in 2025. The tax brackets also remains the same. The corporate income tax rate is divided into two brackets. In the first bracket, you pay the 19% rate over profits of up to €200,000. So if you make a profit of up to €200,000 you pay up to €38,000 vpb.  

Does your bv’s profit exceed €200,000 euros? The amount over €200,000 euros falls into the second bracket. A rate of 25.8% applies to this second bracket. See an overview of the 2024 tax rates. 

Plans affecting director-major shareholders

Is your business a bv (private limited company)? Then the bv must pay corporation tax every year. Do you own more than 5% of the shares and also work in the bv? Then you have a ‘substantial business interest’ and are a director-major shareholder (DGA). As a DGA, you deal with taxation in box 2. These are the plans affecting DGAs.  

Reversal of increase in box 2  

The government wants to reduce the rate in the second bracket of box 2 from 33% to 31%. The measure is a reversal of a previous increase. This taxation affects DGA’s, as they must pay tax in box 2 on dividend payments or share profits, for example. 

The rate in the first bracket of box 2 remains 24.5%. The government proposes that DGAs go back to paying 31% income tax in 2025 if the ‘income from substantial business interest’ exceeds €67,804 and so falls into the second bracket.  

If the rate in Box 2 goes down in 2025, it may be more attractive for entrepreneurs to wait till then to pay dividends. 

Please note: it is not yet certain when the amendments to the law will take effect

A legislative amendment must first be approved by the Lower and Upper Houses of parliament (Tweede en Eerste Kamer). After publication in the Staatsblad or Staatscourant (Government Gazette, in Dutch), the law can take effect.

An Order in Council (Algemene Maatregel van Bestuur, AMvB) or ministerial decree also applies only after publication in the Staatsblad or Staatscourant.

Find out more

Visit Business.gov.nl to see the complete overview of government plans that are important to your business. Or find out more about Budget Day on KVK.nl.