All articles · 2026-01-16 · Taxation
The withholding tax (roerende voorheffing) up and liquidation reserves (liquidatiereserves) in motion: what should you do as an entrepreneur now?
The new year has begun, and as an entrepreneur, that feels… ambivalent. Not because January is suddenly magically “a new chapter,” but because 2026 especially…
By Jan Hermans, CEO & founder of Lyff.
“How do I extract money from my company in the smartest way?”
Dividends, liquidation reserves (liquidatiereserves)... these are all possibilities you can use to take money out of your company. However, these possibilities are being re-evaluated. What exactly is changing? And most importantly... When will everything change?
liquidation reserves (liquidatiereserves): 15% becomes 18% (and no one knows when)
What's on the table: the withholding tax (roerende voorheffing) on liquidation reserves (liquidatiereserves) will increase from 15% to 18%. And since that change wasn't annoying enough, it's also unclear when this new law will become active. This rightly makes entrepreneurs nervous, leading to panic decisions.
That's a dangerous reflex. Not because speed is always wrong, but because emotional decisions are almost always fiscally suboptimal.
the problem is not the measure, but the yo-yo policy
The rules surrounding liquidation reserves (liquidatiereserves) have already been adjusted several times in recent months. And as an entrepreneur, you naturally have no choice but to build your strategy on what is communicated by politicians. If those laws are then also adapted very quickly, entrepreneurship becomes synonymous with gambling.
The real question you, as an entrepreneur, need to ask is:
“What laws are currently applicable, and which choices are already rational today, even if it changes later?” Because yes: it will change. But that's no excuse to do nothing. We advise our clients to take serious action as soon as a law is published, it is clear when the law will come into effect, and we know with certainty what the impact of that law will be.
Whether you agree with that political logic or not: you must make your plan with the knowledge that taxation will remain volatile in the coming years.
What you should do now (without panic, with numbers)
Invest some time now and do an exercise with your accountant and/or your advisor where you sharpen three things:
Step 1 — Create a cash-out roadmap (12–24 months)
Map out:
- how much private income you need
- what distributions your company can handle without stress
- what timing is logical (not “because it might change soon”)
If you can't explain this on a single A4, you don't have a plan.
Step 2 — Simulate scenarios: 15% vs 18% vs “even worse”
Have calculations made in black and white:
- what the difference is for your amounts
- what “accelerating” costs or yields
- what it does to liquidity and future options
No simulation is the same as working with opinions. That leads to bad decisions.
Step 3 — Choose a strategy that also works if rules shift again
That means:
- don't put all your eggs in one basket (technique)
- don't blindly shout “dividend!” or “liquidation reserve!”
- do: mix based on your profit, cash, horizon, risk, and private needs
Stop waiting for “definitive news”
If you keep waiting until everything is “certain,” you will always be too late. You avoid decisions because you don't want to choose incorrectly. But you choose anyway, even by doing nothing.
Better a painful plan based on elaborated scenarios than no plan based on hope.
The math behind the waiting period: why deciding now pays off
Within the control room of your Lyff. management company, time is your most valuable asset. With the liquidation reserve (liquidatiereserve), you buy tax discounts with patience. Since the recent harmonization, you have to wait three years to benefit from the reduced rate. But beware: those three years are a real block per annual allocation. Money that is tied up loses purchasing power due to inflation. In my book, I describe this as the 'economic cost of taxation'. If you hesitate now because the withholding tax (roerende voorheffing) increases from 15% to 18%, you often forget that stagnant cash in a checking account already costs you 2% to 3% in real value each year.
Take the example of a company with 100,000 euros profit. After corporate tax (vennootschapsbelasting) and the anticipatory levy (anticipatieve heffing) of 10% upon allocation, you park a reserve. If you wait three years, you might pay 18% instead of 15%. On a net distribution of 70,000 euros, we're talking about a difference of 2,100 euros. That's annoying, but no reason for blind panic. The real mistake is letting the money lie idle while waiting for political clarity. You can already make that reserve generate returns within the company via a branch 6 contract (tak 6-contract) or DBI-fund, whereby the return more than compensates for the tax increase.
The VVPR-bis route: an alternative for your liquidity
Besides the liquidation reserve (liquidatiereserve), there is the VVPR-bis regime. Here too, timing is crucial: the reduced rate is only accessible from the fourth financial year after the contribution. In my practice at Lyff., I often see entrepreneurs who start too late with this 'shoebox with taps'. Those who start today build leverage for later. The advantage? You don't build up frozen reserves as with the liquidation reserve (liquidatiereserve), but you create a right to a favorable dividend in the future.
Want to know which mix is optimal for you? Read more about our approach to /nl/diensten/fiscale-optimalisatie or delve into the concrete mechanisms in my book via /nl/boek.
Frequently Asked Questions
Does it make sense to still create a liquidation reserve (liquidatiereserve) now if the rates increase?
Yes, provided it fits into your long-term planning. Even with an 18% withholding tax (roerende voorheffing), the total tax burden (corporate tax (vennootschapsbelasting) + 10% levy + 18%) remains significantly lower than if you distribute the same amount as salary, where the burden rises to over 50%. The point is that you only tie up money that you genuinely do not need privately in the next three years.
What happens to my reserve if I prematurely liquidate my company?
In the event of an effective liquidation of the company, the 0% withholding tax (roerende voorheffing) rate applies to the established liquidation reserves (liquidatiereserves). This is the ultimate shortcut for those planning an exit. However, if you have only recently established the reserve and distribute it without liquidation, the tax penalty will be severe. Good /nl/diensten/vermogensbescherming begins with knowing these small print details.