If you own a BV as a director-major shareholder (DGA), the cabinet's plans of 29 September 2026 affect you twice. The higher box 2 rate would fall from 31% to 29.2% for four years from 2027. The limit for borrowing from your own BV before box 2 tax applies would drop from €500,000 to €100,000. Both are proposals and not yet law.
The two measures point the same way. A lower rate makes it cheaper to pay out dividend, while a lower borrowing limit makes it less attractive to leave money in the BV and borrow it privately. This article explains what the current rules are, what the cabinet proposes and what it could mean for the value of your BV and your debts to it.
Box 2 in 2026 and the proposed rate
Box 2 taxes income from a substantial interest, usually a holding of 5% or more in a company, such as the dividend you pay yourself as a DGA. According to the Belastingdienst, the rate in 2026 is 24.5% up to €68,843 and 31% above that amount. Fiscal partners can divide their box 2 income between them in any proportion, so each can use the lower bracket.
In its letter to parliament of 29 September 2026, the cabinet proposes to lower the rate in the second bracket by 1.8 percentage points to 29.2% from 2027, for a period of four years. The cabinet writes that this should encourage entrepreneurs to take money out of their company at a lower rate. For a DGA who pays out €300,000 in dividend, the lower rate would save about €4,160 in tax, based on the 2026 bracket limit.
Borrowing from your own BV: the current rule
Since 2023, DGAs who borrow a lot from their own BV pay tax on the excess. According to the Belastingdienst, the limit was €700,000 in 2023 and has been €500,000 since 2024. What counts is the total you and your fiscal partner owe to your BVs on 31 December, and the amount above the limit is taxed in box 2 as if it were dividend.
Loans for your own home are left out, provided the BV has a mortgage right on the property. For home loans that already existed at the end of 2022, that mortgage right is not required.
The proposed phase-down to €100,000
The cabinet wants to reduce the limit to €100,000 in five steps of €80,000, starting in 2027, while home loans remain excluded. The letter does not list the limit for each year. If the steps are taken once a year from 2027, the limit would be €420,000 in 2027, €340,000 in 2028, €260,000 in 2029, €180,000 in 2030 and €100,000 in 2031. That schedule is our reading, although the budget table in the letter does show revenue from this measure in each year from 2027 to 2031.
If you owe €400,000 to your BV for anything other than your home, the proposal would mean paying box 2 tax on part of that debt within a few years, or repaying it first. Repaying can be done by paying out dividend and using it to settle the loan, which is exactly the kind of transaction the temporary lower rate is meant to encourage.
What still has to happen
These are plans in a letter to parliament, not law. The letter presents the box 2 measures as part of the cabinet's amending bill for box 3, which it wants the Eerste Kamer to pass before 31 December 2026, and the details can still change. The box 3 part of the plans is covered in our article on the box 3 proposals of September 2026.
How Gylder fits in
Gylder (gylder.nl) is a net worth tracker, not a budgeting app. You can add your shares in your BV as a business stake and a loan from your BV as a debt, each with a dated valuation. That keeps both sides visible in your net worth, which helps when you decide whether to repay the loan or pay out dividend.
What this doesn't tell you
The tax effect depends on your own situation, including your fiscal partner, other BVs and the value of your home loan. The figures here are simplified examples and not a calculation for your company. This article is general information, not financial or tax advice, and for decisions about your BV a tax adviser is the right person to talk to.
Frequently asked questions
What is the box 2 rate in 2026? In 2026 the box 2 rate is 24.5% on income up to €68,843 and 31% above that amount.
What did the cabinet propose for box 2 in September 2026? It proposed to lower the higher box 2 rate to 29.2% for four years from 2027 and to reduce the limit for borrowing from your own BV before box 2 tax applies to €100,000, in five steps of €80,000.
How much can I borrow from my BV without paying tax in 2026? In 2026 the limit is €500,000, measured on 31 December together with your fiscal partner. Loans for your own home with a mortgage right for the BV are not counted.
Is the lower box 2 rate already law? No. It is a proposal in a letter to parliament of 29 September 2026 and still needs approval from both houses.