From 2025, the rate at which income from substantial interest (box 2) is taxed will be reduced from 33% to 31%. The rate on income in box 2 up to € 67.804 (2024 to €67,000) is lower: 24.5%. For tax partners, this rate step applies per person, so that together they are up to € 135.608 (2024: €134,000) of substantial interest income at the rate of 24.5%.
How much dividend in 2024
In our article (How much) dividend to be paid in 2024 we already write that, in view of the drop in the rate in 2025, it is in principle not interesting to enjoy more than €67,000/€134,000) in substantial interest income in 2024. DMSs who enjoy no other income in box 2 can pay dividends up to this amount in 2024.
Tax snag
DMSs who want to take dividends from their BV in 2025 under the low rate of 24.5% should keep an eye on a tax snag. That concerns a change in the application of the general tax credit (AHK). That is the rebate every Dutch citizen gets on his/her income tax liability. The AHK is €3,068 in 2025 (a lower AHK applies to state pensioners). But this rebate is reduced when income exceeds €28,406 (this amount is not finalised at the moment). The reduction amounts to 6.337% of the income above €28,406.
Until 2024, the reduction in the AHK is calculated only on income from work and home (box 1). From 2025, income from substantial interest (box 2) and income from savings and investments (box 3) will also be included in the calculation of the reduction in the AHK. As a result, marginal rate for substantial interest income in 2025 may be substantially higher than 24.5%.
A sum
As an example, let's take a DGA who receives a salary equal to the customary wage from his private limited company: €56,000. There is no other income in box 1 and the balance of this DGA's assets in box 3 is less than the tax-free assets. This DGA owes €14,343 in tax on his salary. This is calculated as follows:
If this DGA pays €20,000 in dividends, he will pay €20,511 in tax on his total income. This is calculated as follows:
The additional tax of €20,511 -/- €14,343 = €6,168 implies a tax burden on the dividend of 30,84%. This is substantially higher than the rate of 24.5% payable on income in box 2 (it is almost equal to the regular rate of box 2: 31%). This is because income in box 2 counts towards the reduction of the general tax credit.
The dividend paid to a DGA with an income in Box 1 of (approximately) €77,000 or more is, however, taxed at 24.5% because the AHK of this DGA as reduced to nil.