What is Box 2 substantial interest tax in the Netherlands?

Box 2 applies to income (dividends and capital gains) from a substantial interest (aanmerkelijk belang) in a company. You have a substantial interest if you own at least 5% of the shares, voting rights, or profit certificates in a company, directly or indirectly. This typically applies to owners of Dutch BVs or NVs.

For 2024, Box 2 tax rates are 24.5% on the first €67,000 of Box 2 income per person, and 33% on the amount above €67,000. Fiscal partners each have their own €67,000 threshold, so a couple can receive up to €134,000 of dividends taxed at the lower 24.5% rate.

Box 2 income includes dividends paid by the company and gains realised on selling shares. To avoid immediate Box 2 tax, many business owners accumulate profits in their BV and pay themselves via salary (Box 1). Salary paid from the BV must meet the gebruikelijk loon (customary salary) requirement, which for 2024 is at least €56,000.

The total effective tax rate for BV owners is the combination of corporate tax (CIT, 19% up to €200,000 profit, 25.8% above) and Box 2 tax on distributions. Careful planning of when to extract profits can significantly affect the overall tax burden.