Once more, there is a new version of Bart De Wever’s “Supernote”, a living document which is being modified almost continuously and which is used as a discussion tool for the coalition talks. The dynamic journey during the second half of January 2025 seems to mark the ultimate endgame for the successful formation of a new federal government in Belgium. During the last week of the month, the final conclave takes place. Either an agreement is reached by 31 January 2025 or it is potentially game over…
The latest version of the “Supernote” (dating back to 17 January 2025) is aiming to bridge the gaps between the coalition partners and at the same time trying to address public concerns. The proposal includes a tax cut of EUR 1 billion, on top of a EUR 5–6 billion tax shift. The reduction of charges would be financed via contributions from the strongest shoulders and via simplifications, reducing favorable regimes, consumer taxes, and pollution charges.
More net salary… but only as of 2027
This should mainly be achieved by increasing the lump-sum tax-free allowance for those individuals who are working (so not for persons receiving unemployment or sick benefits). This should result in a higher net income as of 2027. Following such a tax reform the greatest benefit would go to wages below the median wage level (currently EUR 3.800 gross per month). Ultimately, the difference between working and not working should amount to EUR 500 net per month.
Furthermore, the abolishment of the special social security contribution, a contribution which was introduced back in 1994 as an additional funding of the Belgian social security, remains part of De Wever’s Supernote.
However, the tax benefit of the “marital quotient” will be phased out. This mechanism allows married or legally cohabiting couples to shift up to 30% of the higher-earning partner’s income to the lower-earning (or non-earning) partner, thus reducing their overall tax burden by taking advantage of the lower progressive tax brackets. If this would no longer be available going forward, it will have a significant negative impact for (married or legally cohabiting) couples where one partner earns little or no professional income. Moreover, it is now foreseen that the tax deduction for alimony payments will continue to exist, however the deduction would be reduced from 80% to 50%.
“Solidarity contribution” of 5%
During the past 7 months, the introduction of a capital gains tax on shares has somehow always been on the menu of Mr. De Wever. This is also the case in the latest version of the Supernote. However, now it is no longer labeled as a “tax” but rather a solidarity contribution. What’s in a name? The objective still remains the same: taxing future realised capital gains on financial assets, which also includes crypto investments. Compared to the previous version of the Supernote, the proposed tax rate of the solidarity contribution is reduced from 10% to 5%. Moreover, the “exempted (or tax-free) amount” (in order to reduce the impact of the solidarity contribution for small investors) is reduced from EUR 10.000 to EUR 6.000 of profit. As capital gains would be taxed, depreciations would become deductible within certain limits.
For unlisted shares, the solidarity contribution would only apply to taxpayers who have an interest of more than 5 percent in a company – the so-called “substantial interest”. For this category of taxpayers, an exemption would be foreseen up to 5 million euros of profit (e.g. when they sell their business).
Employees who receive stock options from their employer will also be subject to the 5% solidarity contribution. This ought to be a compensatory measure for the fact that stock options (within the Belgian stock option legislation) are typically not subject to social security contributions. A specific regime would be introduced for small and medium sized enterprises.
Addressing improper use of management companies
To curb tax optimization through management companies, the minimum managerial remuneration (towards the company director) required to qualify for the reduced corporate income tax rate will be increased.
It is anticipated that 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, would remain. But an additional condition would become applicable. This beneficial regime would only remain in place if the company pays the minimum managerial remuneration towards the company director. This condition will particularly be important in practice for management companies and SMEs where the company director receives insufficient salary. 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. The Supernote proposes to increase the moveable withholding tax rate on liquidation reserves from 5% to 6.5% and reduce the waiting period from five years to three years. This change will raise the effective rate from 13.64% to 15%, which is similar to the VVPR-bis regime. The mechanism of the VVPR-bis regime allows small companies to distribute dividends at a reduced rate. It seems that this VVPR-bis regime will remain intact. Early distributions (within the three-year period) will be taxed at the normal moveable withholding tax rate of 30%.
Copyrights regime
The Supernote also includes a striking passage about the beneficial tax regime for copyrights, which was significantly tightened two years ago by Finance Minister Vincent Van Peteghem (CD&V). The reduced movable withholding tax rate would be increased from 15% to 20% percent. However, digital professions (e.g. IT-programmers) would again be able to benefit from the reduced tax rate.
New deduction for self-employed individuals
Similar to the previous versions of the Supernote, the proposal includes a new deduction for self-employed individuals.
Reform of the stock exchange tax and revival of the Cooreman-De Clerq law
To encourage (sustainable) investments, it is anticipated that the transaction tax on the buying and selling of securities will be reformed. Furthermore, De Wever plans to revive the Cooreman-De Clerq law, which was initially introduced in the 1980s to promote Belgian shares among households.
Increase of the tax on securities accounts
Currently, there is a 0.15% tax on securities accounts with balances exceeding 1 million euros. De Wever proposes to increase this rate to 0.25%.
Phase-out of federal interest deduction
The phase-out of the existing federal interest deduction still remains in De Wever’s Supernote. The federal interest deduction is the only remaining tax benefit related to loans for non-primary residences (when a taxable cadastral revenue is included in the tax return).
It is important to note that no amount or (tax) rate is set in stone. The parties Vooruit and CD&V still find De Wever’s proposals unbalanced and fear that the tax measures affecting businesses and investors will, in reality, generate much less revenue than anticipated.
The clock is ticking. If no agreement is reached by the end of January 2025, the government formation process could collapse, sending negotiations back to square one. Much is at stake and we will continue to provide updates as developments unfold and potential tax measures become more concrete. More news to come.
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
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