The basic deduction would apply at a rate of 10% for SMEs to investments that are used sustainably for the business activity and generate future economic benefits. An additional deduction of 10% would be available for investments in digital fixed assets, such as software and equipment for digital payment and accounting systems, digital CRM-systems, e-commerce platforms, and digital security systems.

The increased thematic deduction is intended for investments and technologies that are socially meaningful and aligned with the sustainable transition. The deduction rate amounts to 40% for SMEs and 30% for other companies.

The increased thematic deduction would be available for investments in the following categories:

• Energy efficiency and renewable energy;

• Zero-carbon transport;

• Environmentally friendly investments; and

• Supporting digital investments related to the three previous types of investments.
  

The eligible investments are to be specified in investment lists (not yet available) that would be updated every three years by the Council of Ministers, in collaboration with the regions. There would be a single list for each category for the entire Belgian territory. To apply the thematic investment deduction, the taxpayer would be required to provide a certificate that the investment is eligible according to the corresponding list.

The increased thematic deduction could not be combined with regional grants, with limited exceptions.

The increased thematic deduction would be welcomed by companies to help support important investment to realize their green transformation. However, the lack of detail currently available on the qualifying investments and the inevitable uncertainty caused by the upcoming Belgian election mean that a degree of prudence and careful monitoring are recommended.

The technology deduction corresponds to the current increased investment deduction for patents and investments in research and development (R&D) which do not have a negative impact on the environment.

For the tax year 2024, the one-time investment deduction for R&D amounts to 20.5% and the spread application to 27.5%. These high percentages are the result of the exceptional inflation rates in 2022. However, the reform stipulates  that the respective percentages should be fixed and therefore no longer subject to indexation. The proposed fixed percentages for investments as from 1 January 2025 are 13.5% for the one-time investment deduction and 20.5% for the spread application.

It should be noted that the technology investment deduction would continue to exclude the wage withholding tax for researchers included in the technology investment value.

Deloitte Belgium can support you in the implementation of the (reformed) investment deduction, the review of eligible investments once the list is published, and obtaining the required certificates.