The normative wage of a substantial interest holder may be lower than the statutory minimum wage after all, if it is for business reasons. Think, for example, of a prolonged situation of loss. The Belastingdienst has stated this.
The tax authorities used to apply the minimum wage as the minimum amount for the normative wage. However, it reversed that point of view. A lower normative wage than the statutory minimum wage may now be assumed if there are objective grounds for setting the wage lower. For example in the situation when the continuity of the company is at risk because it has been suffering losses for some time. The same applies to start-ups and new businesses.
If you want to be sure about the normative wage to apply, you can contact the Belastingdienst through the ‘Verzoek vooroverleg’ (Request for prior consultation) form. At rendement.nl/fiscaaltools (Dutch) you will find a checklist of what to expect during such a consultation.