The new Belgian federal government (Arizona Coalition) has been established and is active since February 2025. Recently, a budget agreement was reached, called the Easter Agreement. With this agreement the government BDW I is aiming to implement a first part of the proposed measures as stipulated in the Government Agreement 2025-2029. Draft legislation was prepared and will soon be introduced before parliament.
Making the expat regime more “attractive” again
As mentioned in our newsflash of the 17th of April 2025, the draft legislation aims to enhance the attractiveness of the Belgian special tax regime for incoming taxpayers and researchers, in order to attract (and retain) international talent in Belgium. The proposed changes under the draft legislation include:
It is important to note that these changes are intended to apply as from income year 2025. However, immediately some practical questions and considerations are triggered for companies, employees and tax practitioners. For instance, what about expats who recently already started working in Belgium and who do not meet the existing salary threshold (so no application was launched for obtaining the expat regime), but what if these persons would qualify under the amended legislation? Will there be any retroactivity? Will it immediately also apply to all existing situations? If so, this may have an impact on for example 2025 year-end payroll calculations, and therefore also on the underlying contracts/assignment letters and subsequent annexes.
In the context of the 2025 budget, the federal government aims to submit the draft legislation for a parliamentary vote as soon as possible but wants to be very thorough in its approach. Once adopted, further guidance and clarification will be needed to understand how these changes will be implemented in practice. We will continue to closely monitor developments and provide updates as more information becomes available.
Increase of net means of subsistence threshold for dependent children
One of the conditions for a child to be considered “dependent” for tax purposes is that his/her own income (net means of subsistence) may not exceed a certain amount. For assessment year 2026, (income year 2025) the below thresholds are applicable based on the current legislation:
In the draft legislation, the federal government proposes to raise this limit to EUR 12.000 (tax year 2026) for all children, promoting equal treatment of all parents regardless of relationship status.
In addition, it is proposed to double the amount of the income from student work (and this in a broad sense) – which is not taken into account to determine the net means of existence – to EUR 6.840 (indexed amount for tax year 2026).
To avoid abuse of the new system (e.g. people having double benefits), persons who receive a minimal ‘subsistence’ income or an equivalent thereof would no longer be considered dependents for income tax purposes.
Scholarships are excluded from the calculation of the net means of existence. Currently, this also applies to scholarships awarded to doctoral students, allowing these students to generally still be considered dependents of their parents. In the draft legislation it is proposed to no longer exclude these doctoral scholarships from the calculation of the net means of subsistence.
All these changes would take effect starting as of assessment year 2026 (income year 2025).
Tax reductions, exceptions and exemptions
As included in the Government Agreement, the new federal government will abolish or update a series of tax reductions and deductions (and we focus here on the sphere of individual income tax), as from income year 2025, including:
Moreover, the federal government proposes to freeze the indexation of certain tax benefits at the level of the amounts applicable for assessment year 2025, and to maintain this freeze through up to and including tax year 2030 (income of 2029). Based on the draft legislation, this list includes the following tax benefits:
This is not a completely new measure, as it concerns the same items for which the indexation has been frozen during the tax years 2021 up to 2024. The new freeze period will be applied for tax years 2026 up to 2030. Consequently, new indexations will take place as of tax year 2031 (income of 2030).
Alimony payments
The tax deduction for alimony payments will be gradually reduced from 80% to 50% as follows:
- 70% for alimony payments paid as from 01/01/2025
- 60% for alimony payments paid as from 01/01/2026
- 50% for alimony payments paid as from 01/01/2027
The taxable part of the alimony payments received will be gradually reduced in the same way.
Alimony payments to beneficiaries in countries outside the European Economic Area (EEA) will no longer be deductible as of income year 2025. Alimony payments made to a person who is not a resident of a Member State of the EEA will, on the other hand, no longer be taxable under the non-resident income tax.
Addressing improper use of management companies
As mentioned in the Government Agreement, there will be changes to the dividends-received deduction (DRD) regime for companies in Belgium. The mechanism of the deduction of definitely taxed income provides that profit distributions from subsidiaries to the parent company are tax-free if they were already taxed at source. The system of “DRD Beveks” which allows entrepreneurs to invest (via an investment company) in shares in a tax-friendly manner, without having to comply with the strict conditions of the DRD-regime, will remain. However, based on the draft legislation, a specific tax of 5% will be introduced on capital gains realised on shares of a DBI-SICAV (insofar as these gains were exempt pursuant to article 192, § 1 of the Belgian Income Tax Code 1992). It will be required that the (receiving) company at least pays the minimum director remuneration (which is currently still set at EUR 45.000 per year).
As included in the Government Agreement, the tax regimes of the liquidation reserve and VVPRbis will be harmonized to the maximum extent. Currently, owners of a company can transfer money from the company to their private assets in a tax-efficient way through the mechanism of a liquidation reserve. As of 1 January 2026 for newly created liquidation reserves, the moveable withholding tax rate on liquidation reserves will be increased from 5% to 6,5% and the waiting period for a tax favourable distribution will be shortened from 5 years to 3 years. This change will raise the effective rate from 13.64% to 15%, which is similar to the VVPRbis regime.
The mechanism of the VVPR-bis regime allows small companies to distribute dividends at a reduced rate. The VVPR-bis regime will remain intact.
Early distributions (within the three-year waiting period) will be taxed at the normal moveable withholding tax rate of 30%.
Self-employed individuals: boosting of the tax credit for own funds
One of the measures which will be introduced to provide additional support to self-employed individuals is the doubling of the existing incentive for own funds. It concerns the tax credit that entrepreneurs with a one-man business (sole proprietorship) are able to receive when increasing their own funds. This tax credit is offset against the personal income tax due, and any remaining balance is refundable. It is calculated based on the increase in equity compared to the highest amount at the end of any of the three preceding taxable periods. Both the rate (from 10% to 20%) and the maximum amount (from EUR 3.750 to EUR 7.500) of the tax credit will be doubled as from income year 2025.
Tax procedure: reforming the tax penalty policy
The program law wants to adapt the current approach to imposing tax penalties. The law will no longer refer to the possibility for the tax authorities to waive the tax increase in the absence of bad faith on the part of the taxpayer. In addition, the law will introduce a rebuttable presumption of good faith on the part of the taxpayer when they find themselves in a situation of non-compliance for the first time. Hence, for initial good faith errors (first mistakes), an automatic penalty of 10% tax increase will no longer be imposed, but the taxpayer will only receive a notice.
Tax procedure: reforming the assessment and investigation period
The assessment and investigation periods that the tax authorities must apply, along with the conditions for the extended limitation period in cases of tax fraud, are being revised once again. This adjustment is made in favor of the taxpayer.
The distinction between the notions of a semi-complex and a complex tax return will be abolished. Under the new category of “complex” tax returns, the assessment / investigation period is 4 years, starting from 1 January of the year to which the assessment year refers.
The assessment / investigation period for establishing taxes in case of tax evasion is reduced from ten to 7 years.
The above will apply retroactively from assessment year 2023.
Access to Central Contact Point (CCP) within the National Bank of Belgium
As part of the intensification of data mining and risk detection (based on certain indicators) by the tax authorities, designated officials will be granted access to the CCP database of the National Bank of Belgium. In addition, a tax auditor may obtain access to the CCP in a specific case after following the prescribed legal procedure. This measure will be introduced in the framework of (the monitoring of) the correct application of the existing annual tax on security accounts, as the tax authorities gain access to information on securities accounts, including opening and closing dates as well as periodic balance information. In addition to securities accounts, cryptocurrency accounts and the amounts held on them will also become visible to the tax authorities.
Tax on securities accounts: no increase
As stipulated in the Government Agreement, the current 0,15% tax rate on securities accounts will remain unchanged (for now).
The current tax on securities accounts was introduced by the Act of 17 February 2021. However, because the anti-abuse provision included in article 201/4, section 6 of that law was annulled by the Belgian Constitutional Court – as it involved an irrefutable presumption – the draft program law includes a new anti-abuse provision based on the Court’s recommendations.
The new anti-abuse provision introduces a rebuttable presumption aimed at countering both the conversion of financial instruments registered in a securities account into financial instruments that are not registered in such an account, and the transfer of part of the securities to a securities account with the same or another financial institution, where these actions cannot primarily be justified by a reason other than the avoidance of the tax.
Thus, when the value of the taxable instruments held in a securities account reaches the taxable threshold immediately before a conversion or transfer and a conversion into instruments not registered in a securities account or a transfer takes place, this conversion or transfer is not opposable against the tax authorities, except when it is primarily justified by a reason other than the avoidance of the tax. Taxpayers will thus be able to prove otherwise.
The new anti-abuse provision is set to take effect on 1 July 2025, and a notification obligation will be introduced to enable effective monitoring of the proposed measure.
Tax deductibility of hybrid cars: a new hope?
The new draft legislation introduces a major change in company car taxation, especially for plug-in hybrid vehicles. The reform reverses earlier plans to phase out tax deductibility for non-electric cars starting in 2026.
Under the new proposal, hybrid vehicles purchased between mid-2023 and the end of 2025—previously under a “transitional regime”—will retain their existing tax deduction rates (up to 75%, and temporarily even 100%) for the full duration of their use. This effectively halts the previously scheduled gradual reduction of tax deductibility for this group.
Additionally, new hybrid vehicles acquired in 2026 and 2027 will also remain eligible for a deduction of up to 75%, while those bought in 2028 will receive a 65% deduction, and those in 2029 will get 57.5%. As of 2030, no deduction will be available for newly acquired hybrid vehicles.
There’s also an extra incentive for low-emission hybrid vehicles (under 50 g CO₂/km): If, based on the gram formula, it turns out that the deductible percentage is higher than 75%, this higher percentage may be applied (with a maximum of 95%) for hybrid vehicles acquired before 31 December 2028. The deductible percentage will then gradually decrease again for hybrid vehicles purchased from 2029 onward. Note that when a vehicle changes ownership, the new owner will be subject to the tax rules applicable on the new date of purchase, lease, or rental.
A key additional update concerns fuel cost deductibility:
These adjustments reflect the government’s recognition that 100% electric mobility is not yet feasible for all business users, due to factors like limited driving range, insufficient charging infrastructure and installation difficulties in urban housing settings.
Finally, the standards for classifying a vehicle as a “fake” hybrid will be adjusted to the new Euro 6e-bis standard. This new European standard will primarily impact new plug-in hybrids, as these vehicles will be subject to stricter testing methods. Hybrid vehicles subject to this new standard will only be considered fake hybrids in Belgium if they emit more than 75 grams of CO2 per kilometer. For other hybrid vehicles, the threshold remains at 50 grams of CO2 per kilometer.
While the reform provides some extra breathing room for hybrid car models, the real impact on company car fleets will depend on future emission standards and evolving EU regulations, especially from 2027–28 onward.
Real estate: phase-out of federal interest deduction
The longstanding federal interest deduction will be abolished from tax year 2026. The federal interest deduction was the only remaining tax benefit related to loans for non-primary residences (when a taxable cadastral revenue for the non-own dwelling is included in the tax return). It is important to note that the abolishment will also apply to existing loans. As from income year 2025, it will thus no longer be possible to deduct paid interest from the immovable income. This will potentially also have an impact in the determination of the tax filing requirement for non-resident taxpayers who only own Belgian real estate.
In line with the abolition of the federal interest deduction, the federal government wants to simplify and unify the federal housing taxation (non-primary residences) by retaining only the “long-term savings” deduction for capital repayments and life insurance premiums.
Other existing schemes, such as “‘federale woonbonus” / “bonus logement fédéral” and “federaal bouwsparen” / “réduction majorée fédérale pour l’épargne-logement”, will be abolished as of assessment year 2026, and the rules for long-term savings will apply to capital repayments and premiums.
Furthermore, the following adjustments are included in the draft legislation:
Flexi-jobs
The remuneration received under a flexi-job employment agreement is exempt from income tax. When the worker is not a retired person, however, the exemption applies only up to EUR 12.000 per taxable period. This amount is not indexed. In alignment with the provisions of the Government Agreement the tax exemption for non-pensioners will be increased to EUR 18.000 as from income year 2025, and subject to further indexation annually.
Reform of the mobility budget
Provisions in relation to the mobility budget are not included in this draft legislation. According to the initial Government Agreement, the mobility budget is set to be reformed into a “mobility budget for everyone”. Although this reform is not part of this draft legislation, it was included in the Easter Agreement and the aim is still to have this into force as from 1 January 2026. Most likely, changes that touch upon the mobility budget will be introduced via a separate law.
New legislation was predicted. A first part of the Government Agreement will be implemented via this draft legislation. But there is much more in the pipeline.
For a deeper discussion on the above, please reach out to your Vialto Partners point of contact, or alternatively:
Philip Maertens
Partner
Nic Boydens
Partner
Bart Elias
Partner
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