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A mortgage for your own home from your holding company can be an interesting financing route for director-major shareholders: the holding company often has assets, a bank charges the market rate, and the mortgage on the owner-occupied home falls outside the €700,000 excessive borrowing limit. When properly arranged, this is a workable option from a tax and legal perspective. When poorly arranged, it results in corrections by the Tax Authorities or even reclassification as dividend. Below are the ground rules.
The short answer
- Possible: yes — a director-major shareholder can obtain a mortgage from their own holding company.
- Conditions: market-rate interest, customary repayment, legally registered mortgage on the property, written loan agreement.
- Exemption for excessive borrowing: mortgage for owner-occupied home does not count towards the €700,000 limit.
- Tax benefit: interest deductible in Box 1 (owner-occupied home), the holding company receives interest income (subject to corporate income tax).
Why take out a mortgage from your own holding company?
Three reasons:
- Available capital. Your holding company often has liquid assets that would otherwise yield a return of ~1–3% at the bank. A mortgage to yourself yields 4–6% interest — more profitable for your holding company than parking it.
- No bank dependency. No AML/CFT investigation, no acceptance issues, no waiting time.
- Flexible terms. You can freely agree on the repayment schedule, fixed/variable interest rate, and term (within market-standard limits).
Disadvantage: the money financing your home is no longer available in liquid form in the holding company for other purposes (investments, exit buffer).
Conditions to get it right from a tax perspective
Three strict conditions for the owner-occupied home exemption within the excessive borrowing scheme:
- The loan is for the owner-occupied home. Purchase, renovation, or maintenance — not for consumption or investments.
- Market-rate interest. Comparable to what a bank would charge for a similar loan. Typically 4–6% in 2024–2025.
- Repayment schedule and mortgage registration. Just like with a bank mortgage — often 30 years annuity or linear, with a mortgage deed at the notary.
If one of these conditions is missing, the Tax and Customs Administration may reclassify the loan as an ordinary loan (falling below the €700,000 threshold) or even as a disguised dividend distribution (directly taxed in Box 2).
What does the structure look like?
- Loan agreement between you (director-major shareholder, private) and your holding company.
- Mortgage deed at the notary — establishment of a mortgage right on your own home in favour of the holding company.
- Interest payment annually or monthly; deductible in Box 1 as mortgage interest (for your private use).
- The holding company receives interest as income — taxed under corporate income tax (~25.8% in 2024).
- Repayment according to schedule.
Notary fees for the mortgage deed: typically €400 – €800.
The tax plate
A calculation example for 2024:
- Mortgage of €400,000 with own holding company at 5% interest.
- Annual interest: €20,000.
- Private (director-major shareholder): interest deductible in Box 1 → savings depend on income tax rate (~37–49.5%). At the 49.5% bracket: ~€9,900 tax saving.
- Holding: interest taxed at corporate income tax ~25.8% → € 5,160 corporate income tax.
- Net effect: savings of ~€4,700 per year compared to a bank mortgage at the same interest rate.
No exact figures — but an indication. The correct calculation depends on your income tax position and the current rates.
Risks and points of attention
- Market-rate interest. Too low = tax adjustment; too high = disguised dividend. Maintain a rate of at least 0.5% above the average Dutch mortgage interest rate.
- Repayment. An interest-only mortgage from a holding company is possible but is viewed critically by the tax authorities. An annuity or linear mortgage is safer.
- Holding capital. Do not “empty” your holding company — retain enough for the operational working capital of any operating company.
- In the event of a home sale or death: the debt to the holding company must be repaid or assumed. Plan this in advance.
Honest recommendation
A mortgage from your holding company is a good instrument if your holding company has sufficient capital and you set up a market-compliant structure. Discuss this with a tax specialist or accountant beforehand — the difference between “fiscally correct” and “fiscally correcting” lies in the details. The savings can amount to thousands of euros per year; the risks associated with poor setup are equally substantial.
For the broader context: current account between BVs and why a holding company.
Frequently Asked Questions
Yes, provided the conditions are met: a market-rate interest, customary repayment, mortgage registration with the notary, and the loan is genuinely for an owner-occupied home (purchase, renovation, maintenance). In that case, it falls outside the €700,000 limit of the excessive borrowing regulations.
Market-rate — typically 4–6% in 2024-2025, comparable to bank mortgages. Interest rates that are too low are adjusted by the tax authorities; interest rates that are too high may be considered disguised dividends. Ask your accountant for the correct percentage.
Yes, provided it is a genuine mortgage for an owner-occupied home — just as deductible in Box 1 as a standard bank mortgage. The holding company receives the interest as income and pays corporate income tax on it. Net, often more advantageous than a bank mortgage at the same interest rate.
No, provided the exception for owner-occupied housing is met. The mortgage for owner-occupied housing does not count towards the excessive borrowing scheme, regardless of the amount. However, the conditions must be correct — otherwise, the exception does not apply.
Yes, in a market-based manner — usually annuity-based or linear over 30 years (like with banks). Interest-only is possible but is scrutinized more closely by the tax authorities and must be strongly substantiated.
Notary fees for the mortgage deed: €400 – €800. Legal preparation (loan agreement): €250 – €500. A consultation with an accountant or tax advisor: €200 – €500. Total €850 – €1,800 for a decent setup.
The mortgage debt to the holding company must be repaid from the sales proceeds, just as with a bank mortgage. Any equity accrues to private ownership. Discuss with a tax advisor whether that equity should be wisely reinvested or distributed as a dividend.
