Choosing between a ZZP (eenmanszaak) and a BV (besloten vennootschap) is the single most important fiscal decision a Dutch freelancer makes. It affects how much tax you pay, who can sue you for what, how much paperwork you do, and what insurance rules apply. This guide compares both structures using verified 2026 rates from the Belastingdienst, KvK and Rijksoverheid — and helps you find your personal tipping point.
1. ZZP vs BV at a glance (2026)
Below is the side-by-side comparison of every meaningful difference in 2026. All amounts come from the official Belastingdienst and KvK pages cited at the end of this article.
| Topic | ZZP (Eenmanszaak) | BV |
|---|---|---|
| Legal entity | No — you and your business are one | Yes — BV is a separate legal entity |
| Liability | Unlimited, personal (incl. private assets) | Limited to BV assets (exceptions for negligence, fraud, personal guarantees) |
| Setup | KvK registration (~€85), no notary | Notarial deed €399–€1,200 (online); €1,500–€2,500 (complex/holding) |
| Profit tax (Box 1 vs VPB) | 35.75% / 37.56% / 49.50% income tax in Box 1 | 19% VPB up to €200k, 25.8% above |
| Self-employed deductions | Zelfstandigenaftrek €1,200 + startersaftrek €2,123 + MKB-vrijstelling 12.7% | None — only applies to Box 1 entrepreneurs |
| Mandatory DGA salary | Not applicable | Minimum €58,000/year in 2026 (€56,000 in 2024/25) |
| Dividend tax (Box 2) | Not applicable | 24.5% up to €68,843, 31% above (per person/year) |
| Annual administration | Bookkeeping €500–€1,500; VAT and IB returns | Bookkeeping €1,500–€5,000; payroll; jaarrekening filed at KvK; VPB return |
| Mandatory disability insurance (AOV) | Planned: BAZ from 2030 (~€171/month max) | DGA exempt under current draft of the BAZ law |
| Tipping point (profit) | Optimal below ~€80k | Usually optimal above ~€100k |
In this article
- 1. ZZP vs BV at a glance (table)
- 2. Liability: unlimited vs limited
- 3. Taxation in 2026 (with rates)
- 4. Administration & real costs
- 5. DGA salary (gebruikelijk loon)
- 6. The tipping point: when does a BV pay off?
- 7. When should you incorporate a BV?
- 8. Holding-BV: the smart default for DGAs
- 9. AOV, schijnzelfstandigheid & insurance impact
- 10. How to switch from ZZP to BV
- 11. FAQ
2. Liability: unlimited (ZZP) vs limited (BV)
For many freelancers, liability — not tax — is the real reason to incorporate. A ZZP is not a separate legal person, so your business debts are your personal debts. Make sure you also have solid contracts with limitation-of-liability clauses regardless of your structure.
ZZP: unlimited personal liability
- • No legal separation between you and your business
- • Creditors can claim savings, car, house, even pension on top of state pension
- • If married in community of property (algehele gemeenschap van goederen), partner is co-exposed
- • A failed contract can wipe out personal finances
BV: limited liability — with exceptions
- • BV is a separate legal entity (rechtspersoon)
- • You only risk the capital you put into the BV
- • Director personal liability for: mismanagement, fraud, unpaid wage tax/VAT, personal guarantees
- • Within the first 3 years after incorporation, directors share liability for some debts (Article 2:248 BW)
3. Taxation in 2026: ZZP income tax vs BV corporate tax
This is where the structures diverge most. For a complete walk-through with all 2026 percentages, see our 2026 tax-rate scorecard with sources and the worked example in gross-to-net 2026. The summary below uses the same verified rates.
ZZP: income tax (Box 1) with deductions
As a sole proprietor your profit is taxed in Box 1 at three progressive rates (2026, under AOW age):
| Bracket | Income (€) | Rate 2026 | Rate 2025 |
|---|---|---|---|
| Bracket 1 | 0 – 38.883 | 35,75% | 35,82% |
| Bracket 2 | 38.883 – 78.426 | 37,56% | 37,48% |
| Bracket 3 | > 78.426 | 49,50% | 49,50% |
On top of these rates, ZZP'ers get three deductions that significantly lower the effective tax burden at small-to-medium profits:
| Deduction | 2025 | 2026 | 2027 (planned) |
|---|---|---|---|
| Zelfstandigenaftrek (self-employed deduction) | € 2.470 | € 1.200 | € 900 |
| Startersaftrek (max 3× in first 5 years) | € 2.123 | € 2.123 | € 2.123 |
| MKB-winstvrijstelling (% of profit) | 12,7% | 12,7% | 12,7% |
BV: corporate tax (VPB) + DGA salary + dividend tax (Box 2)
A BV is taxed twice: once on company profit (VPB), once when money leaves the BV (salary in Box 1 or dividend in Box 2). The trick is the lower headline rate of 19% VPB on the first €200,000 of profit — but the total burden depends on whether you actually take the money out.
| Tax | Rate 2026 | When it applies |
|---|---|---|
| VPB bracket 1 | 19% | On first €200,000 of BV profit |
| VPB bracket 2 | 25,8% | On BV profit above €200,000 |
| Box 2 bracket 1 | 24,5% | Dividend / box-2 income up to €68,843 (per person/year) |
| Box 2 bracket 2 | 31% | Dividend / box-2 income above €68,843 |
| Dividend withholding tax | 15% | Withheld at distribution; offset against Box 2 |
4. Administration & real costs
A BV adds three permanent cost categories: payroll administration for the DGA salary, a deposited annual report (jaarrekening), and a separate corporate tax return (VPB). Combined with higher bookkeeping rates, expect the BV to cost €2,500–€4,000 per year more than a ZZP.
| Cost item | ZZP (eenmanszaak) | BV |
|---|---|---|
| Setup | €0–€85 (KvK only) | €399–€1,200 (online notary) or €1,500–€2,500 (holding) |
| Annual bookkeeping | €500–€1,500 | €1,500–€5,000 |
| Annual report (jaarrekening + deponering) | Not required | €600–€1,800 |
| Payroll administration (DGA) | Not applicable | €200–€600/year for monthly payslips |
| Corporate tax return (VPB) | Not applicable | Usually included in BV bookkeeping fee |
| Notary for changes (shares, transfers) | Never needed | €350–€1,000 per notarial deed |
5. DGA salary (gebruikelijk loon)
If you own ≥5% of a BV and work in it, you are a director-major shareholder (DGA) and must pay yourself a gebruikelijk loon — a salary deemed customary for your work. This rule prevents avoiding Box 1 income tax by paying only dividends.
| Year | Minimum DGA salary |
|---|---|
| 2022 | € 48.000 |
| 2023 | € 51.000 |
| 2024 | € 56.000 |
| 2025 | € 56.000 |
| 2026 | € 58.000 |
The salary you pay yourself must in principle be the highest of three values: (1) €58,000, (2) the wage of the most comparable employment, or (3) the wage of the highest-earning employee in the BV or affiliated entities.
6. The tipping point: when does a BV actually pay off in 2026?
Until a few years ago the rule of thumb was "BV from €150,000 profit". With the zelfstandigenaftrek dropping from €7,280 (2019) to €1,200 (2026) and further to €900 in 2027, the tipping point has moved significantly. Most accountants now place it between €90,000 and €120,000 profit in 2026, depending heavily on whether you distribute or retain profit. Use our tax calculator to model your own situation.
ZZP wins almost every time. Combined deductions and credits beat the VPB advantage easily.
Grey zone. Pure tax saving (~€2–5k) often gets eaten by BV admin costs. Liability or pension may tip the scale.
BV usually wins, especially if you retain profit. The advantage grows with every euro above €100k.
Worked example: €120,000 profit in 2026
The example below uses verified 2026 rates. It excludes heffingskortingen and Zvw-bijdrage on both sides for clarity — those work out roughly equal at this income level (see bruto naar netto 2026 for the full mechanics).
ZZP (eenmanszaak)
Profit: € 120.000
Zelfstandigenaftrek: − € 1.200
MKB-vrijstelling 12.7%: − € 15.088
Taxable income: € 103.712
Income tax bracket 1 (€38,883 × 35.75%): € 13.901
Income tax bracket 2 (€39,543 × 37.56%): € 14.852
Income tax bracket 3 (€25,286 × 49.50%): € 12.517
Tariefmaatregel (11.94% × €16,288): + € 1.945
Total IB (≈): € 43.215
+ Zvw 4.85% on max bijdrage-inkomen €79,409 = €3,851
BV (€58k salary, rest as dividend)
DGA salary (Box 1): € 58.000
BV profit before VPB (simplified): € 62.000
VPB 19%: − € 11.780
Profit after VPB (available for dividend): € 50.220
Box 1 tax on €58k salary: € 21.080
VPB on BV profit: € 11.780
Box 2 (24.5% × €50,220 dividend): € 12.304
Total tax (≈): € 45.164
+ Zvw low rate 4.85% × €58,000 ≈ €2,813 (withheld from DGA salary — most DGAs are not insured for werknemersverzekeringen, so no employer levy applies)
At €120,000 profit, the pure income/profit tax is close (ZZP ≈ €43,215 IB, BV ≈ €45,164 IB+VPB+Box 2 — within ~€2,000) when the BV distributes everything as dividend. Heffingskortingen typically favour the BV side slightly (a €58k salary triggers more arbeidskorting and algemene heffingskorting than €103k taxable ZZP income), narrowing or reversing this gap. The BV gains its real advantage when you retain profit: pay only the 19% VPB now (€11,780), defer the Box 2 layer (€12,304) until you actually withdraw.
This is why most accountants place the real tipping point around €100,000 profit: below that, the BV admin overhead (€2,500–€4,000/year) eats the tax saving, especially if you distribute most profit.
Caveat: numbers rounded, exclude heffingskortingen and the Zvw row. ZZP Zvw is paid via inkomstenbelasting at 4.85% on bijdrage-inkomen (max €3,851); a non-insured DGA pays roughly €2,813 low-rate Zvw on €58k salary. Run your specific situation with an accountant before switching.
7. When should you incorporate a BV?
Tax is one trigger; it is rarely the only one. Below are the five clearest signals that incorporating makes sense in 2026.
1. Sustained profit > €100,000
Pure tax advantage materialises once profit clearly exceeds €100k for at least two consecutive years. A single peak year is rarely worth it.
2. You retain profit instead of withdrawing it
The biggest BV advantage is deferral: pay 19% VPB now, decide later whether to distribute. If you spend every euro you earn, this matters far less.
3. Real liability exposure
Large contracts, design-and-build assignments, software supply chains, financial advice — anywhere a single mistake could cost €100k+. Insurance helps, but a BV adds a second wall.
4. You're building something to sell
Selling shares (BV) is far cleaner than selling a sole proprietorship's assets piecewise. A holding-BV makes the eventual exit tax-efficient via the deelnemingsvrijstelling.
5. Multiple owners or investors
A ZZP can have only one owner. As soon as a partner, co-founder or investor needs equity, you need a BV (or VOF — which keeps unlimited liability).
6. Specific clients prefer a BV
Since the Belastingdienst resumed enforcement of schijnzelfstandigheid in 2025, some large corporates and government bodies only contract via a BV. Sometimes the BV pays for itself in winning a single big assignment.
8. Holding-BV: a strong default when retaining profit
If you incorporate and plan to retain profits or scale, most Dutch accountants recommend a holding structure: a personal Holding BV that owns 100% of an operating BV (Werk-BV). The Werk-BV invoices clients and pays your salary; the Holding-BV receives dividend tax-free thanks to the deelnemingsvrijstelling. For a simple solo freelancer who distributes all profit each year and has no growth plans, a single BV without holding can be cheaper to run. Three concrete benefits of the holding model:
- Risk separation. Operating losses or lawsuits hit the Werk-BV. Pension, real estate or savings parked in the Holding stay safe.
- Tax-free upstream dividends. The Werk-BV can pay net profit up to the Holding without paying Box 2 immediately. Box 2 only triggers when you personally take money out of the Holding.
- Clean exit. Selling the shares of the Werk-BV from a Holding can be fully exempt via the deelnemingsvrijstelling — meaning zero VPB on the sale gain.
9. AOV, schijnzelfstandigheid & insurance impact
Two upcoming policy shifts affect ZZP vs BV in 2026 more than tax does:
Mandatory AOV (Wet basisverzekering arbeidsongeschiktheid zelfstandigen)
The original 2027 deadline has been postponed to 2030. Under the current draft (BAZ-bill), self-employed people who file income tax as an entrepreneur pay up to ~€171/month (indexed to the 2025 minimum wage). The benefit is 70% of taxable profit capped at the minimum wage, with a 2-year waiting period. Crucially, DGAs of a BV are excluded in the current draft, alongside entrepreneurs with significant employment income and those at AOW age. For ZZP\'ers, this could effectively add €2,000+ to annual ZZP costs from 2030.
Schijnzelfstandigheid enforcement
Since 1 January 2025 the Belastingdienst has resumed enforcement of false self-employment. The structure (ZZP or BV) is not the deciding factor — the real working relationship is. A BV with one client, fixed hours and no entrepreneurial risk can still be reclassified as employment. That said, in practice some sectors (IT contractors at large corporates, government interim management) increasingly require a BV as a baseline. Read our full guide on schijnzelfstandigheid in 2026 for the criteria and recent rulings.
10. How to switch from ZZP to BV
Switching is a one-off project that typically takes 4–8 weeks. The two routes:
- Geruisloze inbreng (silent contribution). Fiscal book values of your eenmanszaak transfer to the BV without immediate tax on the hidden reserves and goodwill. Strict conditions: full continuation of the business, contribution within 9 months of the chosen transition date, BV is incorporated in the Netherlands. Most common route for established freelancers.
- Ruisende inbreng (noisy contribution). You pay stakingswinst now, but the BV gets fresh tax book values (typically higher = more depreciation later). Sometimes preferable when there\'s low goodwill or you can offset stakingswinst against losses.
- Have an accountant calculate stakingswinst, goodwill and whether geruisloze inbreng is fiscally favourable.
- Sign an intentieverklaring before the chosen transition date (often 1 January).
- Notary drafts and passes the deed of incorporation (consider adding a Holding-BV if you plan to retain profit or scale).
- Register the BV at KvK, the Belastingdienst issues VPB and payroll numbers.
- Transfer client contracts, bank accounts, software subscriptions, domain names and insurance to the BV.
- Set up payroll (loonadministratie) — DGA salary starts in month 1 of the BV.
- Deregister the eenmanszaak at KvK after the final IB return is filed.
11. Frequently asked questions
Can I pay myself less than €58,000 as DGA in 2026?
Only with solid evidence that the customary salary in the most comparable employment is genuinely lower, when working part-time (pro rata), or when the BV is structurally loss-making. The starter exception expired on 1 January 2023, so new BVs no longer qualify for the lower starter rate. Without documentation, the Belastingdienst will impose corrections.
Is the minimum capital still €0.01?
Yes. Since the introduction of the Flex-BV in 2012, you only need €0.01 starting capital. The notary fee and KvK registration are the real minimum costs.
What about a VOF or maatschap instead of a BV?
VOF and maatschap are Box 1 partnerships — like multi-owner ZZPs. They keep the zelfstandigenaftrek and MKB-vrijstelling for each qualifying partner, but also keep unlimited liability. For two founders below the €100k tipping point, a VOF is often cheaper than a BV. Above it, almost always a BV with two equal shareholders.
Can I lend money from my BV to myself?
Yes, but the Wet excessief lenen bij eigen vennootschap caps debt to your BV at €500,000. Qualifying eigenwoningschuld is excluded, but for debts taken on from 2023 onwards the BV must have a mortgage right (recht van hypotheek) on the home to qualify. Above the threshold, the excess is taxed as Box 2 income at 24.5%/31%. The temporary higher threshold expired in 2023.
What happens to my fiscale oudedagsreserve (FOR) when switching to a BV?
The FOR was discontinued for new build-up from 2023, but existing balances remain. On geruisloze inbreng you can transfer the FOR to a pension liability in the BV; otherwise it is taxed as stakingswinst. This is one of the technical details where an accountant easily earns back the fee.
Does Box 3 wealth tax differ between ZZP and BV?
Indirectly, yes. Cash held in your private name (or in a ZZP, which is the same thing legally) sits in Box 3 above the tax-free threshold (€59,357 per person in 2026, €118,714 with fiscal partner — a planned reduction to €51,396 was scrapped). Cash retained in a BV does not appear in your Box 3 — but you do pay 19% VPB now and Box 2 later when distributing. For freelancers with significant savings, the BV can shield wealth from the high Box 3 fictitious yield.
Key takeaways
Sources & further reading
- Belastingdienst — Box 1 brackets and rates 2026
- Belastingdienst — Vennootschapsbelasting tarieven
- Belastingdienst — Box 2 (aanmerkelijk belang)
- Belastingdienst — Zelfstandigenaftrek 2026
- Belastingdienst — MKB-winstvrijstelling 2026
- Belastingdienst — Gebruikelijk loon DGA
- KVK — Eenmanszaak of BV: rechtsvorm kiezen
- KVK — Verplichte AOV uitgesteld tot 2030
- Rijksoverheid — Wet basisverzekering arbeidsongeschiktheid zelfstandigen (BAZ)
- ZZP Tax Rates 2026 — Full scorecard
- Gross-to-Net for Freelancers 2026
- ZZP Tax Calculator
- False self-employment enforcement 2026
- Zelfstandigenaftrek & startersaftrek explained