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.
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.