Tax Plan DGA 2024

After a radical package of changes as a result of last years tax plan, you as a  DGA  (Director Major Shareholder) will have less involvement regarding fiscal changes in 2024. For example, the Corporate Income Tax rate remains the same, but the dividend payment is taxed more heavily. Do you want to know what else you may have to deal with? In this article we will discuss 8 proposed measures from the Tax Plan in 2024.

Please note: the Tax Plan is not yet final. Though the House of Representatives has approved the plans as of October 30th, the Senate has yet to decide on this. It is customary for proposed plans to become policy in the new year. Lupacompany will keep you informed about this.


1. From 1 to 2: Significant Interest rate changes. (Aanmerkelijk Belang)

From 2024, there will be two brackets in bracket 2 for income tax, 24.5% and 31%. For bracket 2 income up to € 67,000, the rate of 24.5% per person will apply. If bracket 2 income is higher, this is taxed at a rate of 31%.

2. Easier donations to charities

As of 1 January 2024, the gift deduction in the  VPB  will be abolished for donations up to €100,000, but donations to charities should be made easier for private limited companies. While, on the one hand, gift deduction is no longer subject to corporate income tax, on the other hand, gifts made through the BV will not be regarded as taxed dividends by the Tax and Customs Administration. Initially, the deduction would also lapse for donations up to € 100,000, but the House of Representatives did not agree to this. The Tax Plan was amended by the House of Representatives at the end of October.

3. Lowering the limit for excessive borrowing for DGA

The limit for excessive loans for DGAs will be lowered from €700,000 to €500,000. DGAs must pay tax in bracket 2 for income tax if their debts exceed this limit. This measure has also been added to the Tax Plan by the House of Representatives as an amendment. The reduction is intended to compensate for the costs of the above-mentioned gift deduction for donations of up to €100,000.

4. Changing business transfer arrangements

The government wants to continue the BOR and the transfer scheme in an adapted form. The transfer of a company should become easier and remain possible.

5. Adjusting the reinvestment reserve (herinvesteringsaftrek)

The government wants to give entrepreneurs the opportunity  to use the reinvestment reserve  in more situations. With a reinvestment reserve, entrepreneurs can defer tax under certain conditions when they sell an asset at a profit (book profit).

6. Extension of energy- and environmental investment deduction

The planned abolition of the energy investment deduction (EIA), the environmental investment deduction and the arbitrary depreciation for environmental investments as of 1 January 2024 will not take place. The arrangements will be extended until 1 January 2029. The percentage of the EIA will be reduced. This was 45.5% and will be 40%.

7. Amendment of the Fiscal Fund for Common Accounts (FGR) transparency

Do you save on tax by using the Common Account Fund? As of 2025, the tax rules for the FGR will be changed: The fund must then become fiscally transparent, so that the value of shares in the fund are counted as bracket 3 assets.

8. Transfer tax on new real estate through share transactions (from 2025)

The government wants to levy 4% transfer tax on the transfer of new real estate through share transactions. Entrepreneurs then pay about the same amount of tax as with the direct delivery of new real estate. Entrepreneurs can register real estate projects that have already started for a transitional arrangement.

Preparing for 2024

As mentioned, the Senate still has to agree to the plans before they become final. But you may want to align your policies and forecasts with the intended changes. Lupacompany is happy to help you with that.

Do you want to read more about Budget Day and the proposed tax plans? On  this webpage   you can find official information from the Dutch Government in English.