On 11 December 2025, the Law on Miscellaneous Provisions was voted on and officially approved. In deployment of the Government Agreement 2025-2929, this new legislation brings important changes to the Belgian expat regime, it is a game changer with respect to family taxation, it is freezing certain fiscal amounts, it allows for a first increase of the maximum employer contribution in the popular benefit of meal vouchers in Belgium, and it abolishes or downsizes a series of tax benefits in the sphere of individual income tax (see our previous posts). Moreover, this recent law also contains a bunch of other new measures. In this newsflash we highlight some of the other tax related items.
Central Contact Point (CCP) and data mining
The Belgian Code of Miscellaneous Duties and Taxes (Code des Droits et Taxes Divers / Wetboek Diverse Rechten en Taksen) is amended to broaden access to and use of data held by the Central Contact Point within the Belgian National Bank. As from 1 December 2026, the Belgian tax authorities will have access to this data for auditing the annual tax on securities accounts, without requiring any prior indications of tax fraud. In addition, balances of securities accounts and crypto asset accounts, including those held with crypto service providers, must be reported to the Central Contact Point, with initial balance reporting covering 31 December 2025 and 30 June 2026. Moreover, a legal framework will now be introduced to allow its use for data mining on the CCP and file selection (often referred to as “Money Control”), which will enter into force 10 days after publication of the law.
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 typically applies only up to EUR 12.000 per taxable period. This amount was not indexed and would make the system of flexi-jobs less interesting over time. Therefore, this tax exemption for non-pensioners will be increased to EUR 18.000 as from assessment year 2026 (income year 2025), and will be subject to further indexation annually.
Tax procedure
The statutory assessment and investigation periods that the Belgian 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 4-year assessment / investigation period in the case of non-filing or late filing of the tax return is maintained. The assessment / investigation period for establishing taxes in case of tax evasion is reduced back from 10 to 7 years. The changes will apply retroactively as from assessment year 2023.
Hybrid cars: further limited (transitional period for) tax deductibility
The government states that it is not yet feasible for everyone to acquire and drive an electric car. In many instances, fossil fuel powered cars are driven by self-employed individuals who operate without an own company. Therefore, a new limited beneficial tax scheme for plug-in hybrid cars (PHEVs) will become available only for self-employed individuals (notably for people who earn profits and gains, but not for self-employed company directors).
It is important to note that companies and legal persons are not in scope. This means that the existing initial Law of 25 November 2021 on the Fiscal and Social Greening of Mobility will remain applicable for these corporate taxpayers. Indeed, the current phase-out regime (with 0% deductibility as of 2028) will remain intact for plug-in hybrid vehicles acquired between 1 July 2023 and 31 December 2025. All costs for hybrid company cars acquired as of 1 January 2026 will thus no longer be tax deductible. No changes there.
The new limited tax deduction scheme for hybrid cars, only applicable for self employed individuals, includes a.o. the following tax measures:
In 2026, electricity costs will follow the deductibility percentage for full electric cars (EVs). For hybrid vehicles (i.e. passenger cars, dual-purpose vehicles and minibuses) purchased, rented or leased as of 1 January 2026, the fossil fuel costs (gasoline, diesel, natural gas) will no longer be deductible for income tax purposes.
5% capital gains tax for DRD-Beveks
The Law of 11 December 2025 on Miscellaneous Provisions brings 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 new legislation, a specific tax of 5% will be introduced on capital gains realised on (the disposal of shares of) a DBI-BEVEK/SICAV-RDT (insofar as these gains were exempt pursuant to article 192, § 1 of the Belgian Income Tax Code 1992). In order to credit the moveable withholding tax on dividends received from such investment vehicles, it will be required that the receiving company at least pays the minimum director remuneration (currently EUR 45.000, but this will be increased to EUR 50.000 and subject to further indexation). The changes will apply as from assessment year 2026 (income year 2025).
Tax credit for ‘own funds’ of entrepreneurs: twice the charm
A measure that is introduced to provide additional support to self-employed individuals is the doubling of the already 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. The purpose is to stimulate entrepreneurs to make investments without having to take out an additional loan. The calculation is based on the increase in equity compared to the highest amount at the end of any of the three preceding taxable periods. Both the percentage (10%) and the maximum amount (EUR 3.750) of the tax credit will be doubled (respectively to 20% and to EUR 7.500), both for self-employed individuals in main occupation and second occupation, as from assessment year 2026 (income year 2025).
Solidarity contribution and Wyinckx contribution for occupational pensions increased
As of 1 January 2026, the solidarity contribution which must be withheld upon payout of an occupational pension capital (and which varies between 0% and 2% of the gross pension amount), will be uniformly set at 2% for the withholding. Moreover, as of 1 July 2027, an additional solidarity contribution of 2% will become due on the portion of such pension capitals which exceeds a threshold of EUR 150.000. As a result, the solidarity contribution will be 4% on the capital above EUR 150.000.
Starting from the contribution year 2026, the so-called Wyninckx contribution, a special social security contribution which is due by employers on high pensions contributions, will increase from 3% to 12,5%.
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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