JJurical
Transfer pricing2 credits

Arm’s length interest on loans between a DGA and their BV

Determine the arm’s length rate for both directions: the DGA lending to their own BV (synthetic rating of the BV on its key figures) and the BV lending to the DGA (personal credit scorecard per EBA guidelines, with a two-pass rate convergence). In both cases: swap rate per term, currency and transaction year plus a credit margin with a full premium build-up.

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dga-loan v1.0.0 · vintage 2026.1 · draft free
Example outcome
Arm’s length rate DGA → BV (fixed)4.02%
Risk-free base — 5Y EUR swap (2024)2.56%
Credit margin — BV rating Aa3, senior unsecured1.46%
Principal — 5 years, EUR€ 500,000
sha256 a3f19c47e8b2d05f6c91a4e7d23b8f50…

Who it’s for

01DGA advisers who must substantiate at arm’s length the interest on a loan or current account from the DGA to the BV.
02Accountants and financial reporters who want the interest charge in the BV’s annual accounts traceable to a verifiable calculation.
03DGAs themselves who want to fix a defensible percentage before signing the loan agreement.

What the tool does

✓ Direction DGA → BV: the BV is assessed on its own key figures (EBIT, EBITDA, interest expense, equity and liabilities)✓ Direction BV → DGA: personal credit scorecard (interest coverage 40%, LTV 30%, DSCR 20%, income stability 10%, per EBA/GL/2020/06) with a two-pass rate convergence and flagging of income concentration above 70%✓ Risk-free base from the swap curve, per term, currency and transaction year (EUR, USD, GBP; 2021–2026)✓ Synthetic rating of the BV with its interest coverage ratio — both the raw band and the final rating appear in the result✓ Credit margin with premium build-up: expected loss, regulatory, market and operational risk✓ Fixed rate as swap plus margin, floored at zero; term from 1 year, above 10 years the tool calculates with 10 years and flags this explicitly✓ Report with report number, tool version, dataset vintages and a verification address where the outcome can be checked independently
01 — Form
Case and key figures — a handful of fields.
02 — Draft
Full outcome layout, free.
03 — Pay and receive
Via Mollie, VAT/VIES handled.
04 — Report
Certified PDF + public hash.

Why the interest on a DGA loan needs substantiation

A loan between a DGA and their BV is a related-party transaction: the Dutch tax authority tests whether an independent third party would have agreed the same rate under the same circumstances. A percentage that merely “seemed customary” rarely survives that test — the inspector wants to know which risk-free curve, which credit quality of the BV and which transaction year underpin the figure.

This tool prices both directions: the DGA as lender to their own BV, and the BV lending to the DGA. Every intermediate step — swap rate, rating or personal scorecard, margin build-up — is in the result, and every report states the tool version and dataset vintages together with a verification address. The same input yields the same outcome years later. If the tool cannot compute your case, it says so in the free draft and nothing is charged.

Frequently asked questions about this tool

Does the tool also price a loan from the BV to the DGA?
Yes. The BV → DGA direction assesses the DGA as a personal borrower via a weighted scorecard (interest coverage 40%, LTV 30%, DSCR 20%, income stability 10%), calibrated to the EBA Guidelines on loan origination. The rate is determined in two steps: first with a 5% rate assumption, then again with the actual rate from the first solve — if the rating changes as a result, the outcome discloses this explicitly. If more than 70% of DGA income originates from the BV, the tool warns about income concentration.
Which loans does the DGA → BV direction support?
Loans with an amount greater than zero, a term from 1 year, transaction years 2021–2026 and currency EUR, USD or GBP. If you enter a term above 10 years, the tool calculates with 10 years and reports that cap. The rate is always fixed, and the BV is priced as senior unsecured: there is no input for subordination or security. If the loan is in fact subordinated, use the Corporate Loan tool, which does support notching.
What happens to the DGA’s personal data?
This tool is classified as processing personal data: the BV → DGA direction uses personal financial fields (income, mortgage, WOZ valuation, assets, pension) for a personal credit assessment. For the DGA → BV direction you do not need those fields: only the BV’s key figures and the DGA’s country of residence are used. Your input is never shared and never used for training or profiling; only the verification hash is public. See the privacy statement for the full arrangement.
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Arm’s length interest on loans between a DGA and their BV — Jurical