Setting up a Savings BV: Benefits for DGAs in 2026

As a DGA (director-major shareholder), you build up capital in your company. But how do you protect that capital against risks? And how do you optimise your tax position? A savings BV could be the answer. In this article, we explain what a savings BV is and when this structure is beneficial.

What is a savings BV?

A savings BV is a holding BV in which you place surplus liquidity and investments. The savings BV is separate from your operating company, which protects the assets from business risks.

The typical structure is as follows:

• You, as the DGA, are the shareholder of the holding BV
• The holding BV is the shareholder of the operating BV (operating company)
• Profit flows from the operating BV to the holding company (participation exemption)
• The holding company acts as a savings BV for the accumulated capital

Benefits of a savings BV

1. Protection of assets

The main benefit: separation of risks. If your operating company runs into trouble or goes bankrupt, the assets in the holding company remain safe. Creditors of the operating BV cannot access the money in the holding company.

Of course, this only applies if you have not had the holding company co-sign for the operating company's debts and if there is no question of directors' liability.

2. Tax advantage on profit distribution

Profit can be transferred tax-free from the operating company to the holding company via the participation exemption. You only pay tax (substantial interest levy) when you withdraw the money from the holding company to your private assets.

This means you can defer the tax liability. The money grows tax-free within the holding company until you need it.

3. Reinvestment without direct taxation

Suppose you sell your operating company. The proceeds of the sale go into the holding company. You can then reinvest this amount without first having to pay income tax. In box 3, you would pay capital gains tax.

4. Pension accrual

The savings BV can be used for pension accrual. Although the tax facilities for pensions under own management have been abolished, there are still opportunities to build up a pension through the holding company, for example, via annuity products.

5. Flexibility

A holding structure offers flexibility. You can place multiple operating companies under the holding company, making it easy to start or divest new activities without adjusting the entire structure.

Tax aspects in 2026

The tax treatment of the savings BV has changed in recent years. Here is the current state of affairs:

Corporation tax

The savings BV pays corporation tax on its profits:

• 19% on the first 200,000 euros of profit
• 25.8% on profits above that amount

Investment returns are subject to these rates, which is often more favourable than box 3 in income tax.

Substantial interest (box 2)

If you pay out dividends or sell shares, you pay a substantial interest levy:

• 24.5% on the first 68,843 euros
• 31% on the excess amount

Participation exemption

Profits and dividends from subsidiaries (in which the holding company holds at least 5% of the shares) are exempt from corporation tax. This makes transferring profits to the holding company fiscally attractive.

When is a savings BV a good idea?

A savings BV is not the best choice for everyone. It is particularly beneficial if:

• You structurally make more profit than you need for your private life
• You want to build up capital for the future (pension, sale)
• You have or want to develop multiple business activities
• You want to spread risks between the holding and operating company
• You want the option to defer taxation

If you need all your profits to live on, a holding structure offers little added value.

Setting up a savings BV

Setting up a savings BV works the same way as setting up a regular BV. You go to a civil-law notary for the incorporation and articles of association. You then register the BV with the Chamber of Commerce (KvK).

If you already have an operating BV and want to create a holding structure, there are two options:

Option 1: Set up a new holding company

You set up a new holding BV and transfer your shares in the operating BV to the holding company. This requires a notarial deed and possibly a tax settlement.

Option 2: Company merger or legal merger

Through a merger, you can reorganise the structure without direct tax consequences. This is more complex and requires expert advice.

Points to consider and risks

Acting on a business-like basis

Transactions between you, the holding company, and the operating company must be on a business-like basis. Loans must be provided at market interest rates, and fees must be at arm's length. Not acting on a business-like basis can lead to tax adjustments.

Excessive borrowing

The Excessive Borrowing from Own Company Act has been in effect since 2023. If you borrow more than 500,000 euros from your BV, the excess amount is taxed as a notional dividend. Be mindful of this when planning your assets.

Future legislation

Tax rules change regularly. What is advantageous now may turn out differently in the future. Take potential changes into account and stay in touch with your accountant and lawyer.

Costs

A holding structure involves additional costs: incorporation costs, administration costs, and costs for preparing annual accounts. These costs must be weighed against the benefits.

Savings BV and shareholders' agreement

If you have a business with partners, it is wise to also make agreements at the holding company level. A shareholders' agreement governs what happens if one of the shareholders wants to leave or passes away.

Conclusion

A savings BV can be an excellent tool for building capital, spreading risks, and deferring taxation. But it is not the right choice for everyone. The benefits must outweigh the additional costs and complexity.

Are you considering setting up a savings BV, or do you want to know if your current structure is optimal? Contact us for a meeting without obligation. We would be happy to review the best structure for your situation with you.