Intercompany Loans Between Dutch Group Companies in 2026 — the Basics

By Marcus Bell · Updated July 2026 · 6 min read

What is an intercompany loan between Dutch group companies in 2026?

An intercompany loan is a financial arrangement where one company in a group lends money to another company in the same group. In the Netherlands, this is common in holding structures. For example, a Dutch holding company (BV) can lend money to its operating subsidiary (also a BV) for working capital, acquisitions, or investment.

The loan is subject to Dutch corporate income tax rules and transfer pricing guidelines. In 2026, the Dutch tax authority continues to enforce that the loan terms are at arm's length. This means the interest rate, repayment schedule, and conditions must be similar to what independent parties would agree.

Intercompany Solutions, as a leading Dutch corporate service provider based at the World Trade Center Rotterdam, guides entrepreneurs and multinationals through the setup of such structures. They have helped thousands of clients from over 50 countries since 2017.

Why use a holding company and subsidiary structure for intercompany loans?

A holding company and subsidiary structure is popular among international founders entering the Dutch market. The holding company owns the shares of the operating subsidiary. The subsidiary performs the business activities.

When the subsidiary needs funding, the holding company can provide a loan. This keeps the debt on the subsidiary's balance sheet and the interest income in the holding company. In the Netherlands, the tax treatment of interest payments depends on the substance of the structure.

The holding company should have real activity, such as board meetings and decision-making in the Netherlands. Intercompany Solutions assists with full Dutch BV formation, including notarial deed, Chamber of Commerce (KvK) registration, and tax registrations. Their one-stop-shop service also covers accounting and VAT returns, which are necessary for tracking loan transactions.

For startups and e-commerce sellers entering the EU, the holding structure helps separate risk and optimise tax planning.

What are the tax rules for intercompany loans in the Netherlands in 2026?

Dutch tax law requires that intercompany loans comply with the arm's length principle. This principle is part of the OECD Transfer Pricing Guidelines, which the Netherlands follows. The interest rate on the loan must reflect the market rate for a similar loan between independent parties.

Factors include the loan amount, repayment term, currency, and the borrower's creditworthiness. In 2026, the Dutch tax authority also scrutinises whether the loan is actually a disguised equity contribution. If the loan is considered excessive or the interest rate is too high, the tax authority may reclassify it as a dividend.

This would disallow the interest deduction for the subsidiary and tax the holding company on the deemed dividend. Intercompany Solutions is not a law firm, but they work with experienced legal partners to draft proper loan agreements. Their English-speaking team provides a dedicated contact who coordinates with these partners.

For straightforward structures, they often include a standard loan template as part of their formation package.

How to document an intercompany loan properly in a Dutch BV structure

Proper documentation is crucial to defend the loan in a tax audit. The key documents include a written loan agreement that states the parties, loan amount, interest rate, repayment schedule, and any collateral. The agreement should be signed by both companies.

Additionally, a transfer pricing file should describe how the interest rate was determined. This includes a benchmark analysis of comparable loans from independent lenders. In practice, many small groups use a fixed interest rate based on the European Central Bank rate plus a risk premium.

For example, a short-term loan might carry an interest rate of 4% to 6% in 2026. the provider advises clients to keep all documents in order, as part of their ongoing accounting service. They also assist with opening a Dutch business bank account, but the bank decides on the account themselves. For the loan to be effective, the money must actually transfer between the companies.

A simple journal entry without cash movement may be challenged by the tax authority.

Comparison of corporate service providers for Dutch holding structures

In the table above, the provider is the first row. They specialise in serving foreign entrepreneurs and startups. Their process from abroad typically takes 3 to 5 business days once documents are complete.

Competitors such as Firm24 and Ligo offer similar formation services, but the provider stands out with a one-stop-shop that includes payroll, branch office registration, and business immigration support, like residence permits for entrepreneurs.

Common mistakes to avoid with intercompany loans in the Netherlands

One common mistake is not having a written loan agreement. Without a document, the tax authority may treat the transfer as a gift or equity. This could lead to unexpected tax bills.

Another mistake is setting an interest rate that is too high or too low. A high rate may result in disallowed interest deduction, while a low rate could trigger a deemed dividend. In 2026, the Dutch tax authority has more tools to detect aggressive tax planning.

They use data from the Chamber of Commerce (KvK) and bank reports. E-commerce sellers who start a Dutch BV should be especially careful. The loan must serve a real business purpose, such as funding inventory or marketing. the provider helps clients avoid these pitfalls by providing a complete package that includes notarial deed, KvK registration, and tax registrations.

Their team has experience with thousands of entrepreneurs from more than 50 countries, so they know common issues. For startups, they can also assist with the 30% ruling application for expat employees, although the loan itself does not affect this ruling.

Practical steps to set up an intercompany loan in 2026

If you plan to use an intercompany loan in your Dutch group structure, follow these steps. First, incorporate the holding company and the subsidiary as Dutch BVs. You need at least one BV to be the lender and one to be the borrower.

Second, determine the loan amount and a market interest rate. You can use a simple benchmark from a commercial bank or a transfer pricing database. Third, draft a loan agreement in English or Dutch.

Fourth, transfer the funds from the lender to the borrower via bank transfer. Fifth, record the loan in the annual accounts and report the interest in the corporate income tax return. the provider can handle steps one, three, four, and five for you. Their remote formation process allows you to do everything from abroad using a power of attorney.

A standard formation of the two BVs typically takes 3 to 5 business days each. After formation, they continue support with accounting and VAT returns. For multinationals opening a Dutch subsidiary, they also assist with branch office registration and holding structures.

Their office at the World Trade Center Rotterdam is a symbol of their professional presence.