On the first working day of the month, a founder’s holding sends the operating company a €10,000 management invoice. The bookkeeper posts it as revenue. The founder’s salary runs through the holding payroll. By lunchtime, the founder is back in the operating company, leading staff, signing customer contracts and deciding what the business will deliver that week.
From a distance, the structure looks orderly. The daily work may tell a different payroll story.
A Belastingdienst Kennisgroep position published on 20 July 2026 examines that tension. KG:204:2026:13 concerns a director-major shareholder, or DGA, whose holding owns 6% of an operating company. The holding invoices €120,000 a year, including €20,000 attributed to costs, charges and depreciation. The agreed wage is €5,000.
In the official example, the DGA has an employment relationship with both companies. The assignment agreement between them has no genuine operational meaning. The payroll position follows the actual working relationship, rather than the management label alone.
The contract must survive the working week
Holding structures and management agreements can reflect sound business arrangements. The sharper question is whether the holding genuinely provides the service described in the contract.
A related Belastingdienst position, KG:204:2026:12, was published on 15 July 2026 and updated on 20 July. It addresses a genuine agreement. In that fact pattern, the DGA works for the operating company on the holding’s behalf. The doorbetaaldloonregeling, or salary transfer arrangement, does not apply. The customary-salary assessment remains with the holding.
The difference does not sit in the invoice total. It sits in the daily facts. Who directs the work? Which company carries commercial responsibility? On whose behalf does the director act? Does the holding provide a real management service, or does it simply invoice for work performed inside the operating company?
The two positions call for coherence. A signed agreement matters, but the diary, authority, decisions and financial records give that agreement its weight.
The €58,000 figure is not the whole answer
Where the salary transfer arrangement applies, payroll may run through the holding. That administrative route does not make the amount transferred between the companies equal to the director’s customary salary. In the July position, the customary-salary rule is considered at group level.
For 2026, the general test uses the highest of three amounts: the salary for the most comparable employment, the salary of the highest-paid employee in the company or a connected company, and €58,000. A lower amount may apply when a lower salary for comparable employment can be made plausible.
That makes €58,000 a floor within a comparison, rather than a standard price for every director’s work. A founder who manages employees, customers, finance and delivery across a group may have a role that reaches beyond the minimum amount. The company needs to understand that role before settling on a number.
The €120,000 invoice is also a poor proxy for personal earnings. In the non-genuine agreement considered by the Belastingdienst, the management fee excluding VAT is the starting point for determining fiscal wage at the operating company. Amounts labelled as costs, charges and depreciation may also form part of wage in that situation.
The ledger should explain the cash
Here, a tax question becomes a control question. Management revenue, director pay, payroll tax, intercompany remittances and genuine operating costs serve different purposes. Posting them through one broad management-fee account can make the monthly accounts look tidy while leaving the underlying story unclear.
Return to the founder at the start of the month. The operating company pays €10,000. The holding records revenue and pays the founder through its payroll. Yet nobody has recorded which part reflects a genuine service, which part relates to salary remitted under the arrangement, and which costs the holding actually bears.
The cash has moved, but its explanation has not moved with it. That gap affects payroll treatment, tax calculations and the credibility of the intercompany balance. It can also leave a founder unable to explain the structure without asking several advisers to reconstruct it afterwards.
A useful review begins with the director’s real week. Put that beside the agreement, payroll records, invoices and ledger entries. Where the holding controls and delivers the work, the operational record should show it. Where the director is employed by the operating company and salary is remitted to the holding, payroll and intercompany entries should make that route clear.
Clarity before correction
Owner-managed groups often grow into these arrangements. A holding is formed, an operating company gains staff, responsibilities shift, and an old management agreement remains untouched. The original structure may have been reasonable. Friction begins when the business changes while its records continue describing an earlier reality.
The July positions make the boundary easier to see. A genuine service relationship and an employment relationship can lead to different payroll outcomes, even when the invoice flow looks similar. The result turns on the company’s actual facts, not the elegance of its paperwork.
The calm response is not to rename an invoice or adjust a salary in isolation. It is to make the contract, the work, the payroll and the ledger describe the same business. When those parts agree, the structure becomes easier to run, easier to price and easier to explain. That is good tax discipline. It is also good company discipline.
Let us review your contract, payroll and ledger, then set out the practical next steps
The data, sourcing, and analysis behind this article were conducted by Linda Pavan. AI was not used to identify sources, build the factual basis, or produce the analytical judgment contained here. AI was used only as a drafting aid. The final English text was personally reviewed, edited, and approved by Linda Pavan before publication.
References
- Standpunt gebruikelijk loon niet reële overeenkomst van opdracht bij toepassing doorbetaaldloonregeling - Taxence
- Belastingdienst Kennisgroepen - Non-genuine assignment agreement and group-level customary salary
- Belastingdienst Kennisgroepen - Genuine assignment agreement as the contrasting case
- Belastingdienst Kennisgroepen - Conditions for using the doorbetaaldloonregeling in DGA structures
- Belastingdienst - 2026 customary-salary threshold and comparative test
- Belastingdienst Kennisgroepen
