{"id":3676,"date":"2025-12-05T07:56:29","date_gmt":"2025-12-05T06:56:29","guid":{"rendered":"https:\/\/vwg.nl\/aftrek-fictieve-loonkosten\/"},"modified":"2025-12-05T07:56:29","modified_gmt":"2025-12-05T06:56:29","slug":"deduction-of-fictitious-labour-costs","status":"publish","type":"post","link":"https:\/\/vwg.nl\/en\/aftrek-fictieve-loonkosten\/","title":{"rendered":"Deduction of fictitious labour costs"},"content":{"rendered":"

For a very specific situation, the Ministry of Finance<\/a> approved the deduction of notional labour costs for the purposes of corporate taxation.<\/p>\n\n\n\n

Canteen Foundation<\/h2>\n\n\n\n

The specific situation concerns a canteen foundation. This is a foundation that operates a canteen on behalf of several sports associations. The canteen foundation's operating surplus is used for the primary activities of those associations.<\/p>\n\n\n\n

This foundation is liable to corporate tax because the foundation runs an enterprise. This is because the foundation structurally realises surpluses (profits), but even if this were not the case, the foundation would be liable for corporate tax because it is in competition with (catering) entrepreneurs who pay income or corporate tax.<\/p>\n\n\n\n

Exemption<\/h2>\n\n\n\n

Corporate income tax has a generic exemption. The condition for the application of that exemption is that the profit in a year does not exceed \u20ac15,000 (or over five years in total does not exceed \u20ac75,000, with loss years set at \u20ac0).<\/p>\n\n\n\n

These amounts were exceeded by the canteen foundation, partly because its profits are caused by the efforts of the association's members, who receive no remuneration for their work.<\/p>\n\n\n\n

Fictitious labour costs<\/h2>\n\n\n\n

Notional labour costs may be deducted when calculating the amount of profit. A prerequisite for this is that it is an entity that promotes a social interest (or has ANBI status). The social interest is promoted if the institution carries out activities primarily aimed at the private interest of members and a high social value can be assigned to it.<\/p>\n\n\n\n

However, the canteen foundation carries out its activities towards the associations, not towards the members of the associations, and is therefore not classified as a social interest institution.<\/p>\n\n\n\n

Approval<\/h2>\n\n\n\n

This means that the foundation has to pay corporation tax on its operating surpluses. The ministry considers this unfair because the foundation houses a task that is actually performed by, for and with the members of the associations. If the associations themselves were to operate the canteen, the associations, it is expected, would not have been subject to corporation tax.<\/p>\n\n\n\n

Therefore, the ministry approves the deduction of notional wage costs for the associations' volunteers, provided that:<\/p>\n\n\n\n