Federal government agreement: Draft program law introduced

A draft program law (Dutch |  French) introduced in the Belgian parliament on 28 May 2025 includes an initial set of tax measures implementing the federal government agreement concluded on 31 January 2025. The draft legislation will now be debated by parliament and is expected to be approved and published in the official gazette by end June 2025.

Key measures

Corporate tax measures

• Dividends received deduction (DRD)—Participation condition: The alternative participation condition to qualify for the DRD (an acquisition value of at least EUR 2.5 million) would require the participation to qualify as financial fixed asset based on Belgian accounting legislation, except for shareholders that are small companies.

Employer measures

• Carried interest: A new specific tax regime for qualifying carried interest derived from carried interest vehicles (defined based on the notion of alternative institutions for collective investments) would be introduced. Individuals would be taxed at a flat rate of 25% on qualifying income.

• Ceiling on employer contributions for employees: employers will no longer need to pay employer social security contributions on salary exceeding a certain threshold (which is still to be determined by Royal Decree).

Taxation of investors

Tax on securities account: Proposed introduction of (i) a specific anti-abuse rule which only applies to transactions aimed at circumventing the annual tax on securities accounts in  situations where  EUR 1 million threshold is met in the initial situation  (ii) a new reporting obligation for intermediaries in some of these situations.

Exit taxation: Potential taxation of Belgian and foreign shareholders of a Belgian legal entity upon emigration of the entity or an assimilated transaction. The part of the equity that is deemed to be distributed to a shareholder to the extent that the dividend relates to assets that are no longer used or retained in Belgium as a result of the operation would be taxed at 30%.

Liquidation reserve and VVPRbis regimes: Alignment of the two regimes.

Indirect tax

VAT regime for demolition and reconstruction: Proposed extension of the existing VAT regime of 6% for demolition and reconstruction to developers as from 1 July 2025 provided that the property would be the main residence of the purchaser or owner for at least five years or the landlord leases the property for at least 15 years to one or more successive tenants as their main residence. The surface area of the property in this case would be limited to 175 square metres. 

Heat pumps: The VAT rate on coal would be increased to 21%, and the VAT rate on the installation of a boiler using fossil fuels would be increased from 6% to 21%, on the renovation of dwellings older than 10 years.

New tax regularization

Permanent fiscal regularization regime: A new permanent fiscal regularization regime would be introduced, offering declarants the opportunity to regularize (federal) fiscal irregularities to obtain fiscal and criminal immunity.

Measures not included in the draft program law

A number of provisions included in pre-draft versions of the program law have not made it to the final draft, including the following:

• The technical amendment to allow the deduction of the DRD from a group contribution received.

• The new 5% taxation of capital gains on DRD Sicav/Bevek.

• The amendments to the investment deduction regime.

• The simplification of investigation and assessment deadlines.

• The amendments to the special tax regime for expatriates

• The temporary increase of the tax deductibility of expenses related to qualifying hybrid cars.

• Changes to individual real estate taxation (interest deduction).

• The overall simplification of personal income tax through the abolition of diverse miscellaneous tax deductions and exemptions.

Stay up to date

A description of each of the tax measures covered by the draft program law is available on Deloitte Belgium’s dedicated webpage.

We invite you to consult our Tax Reforms Hub to stay up to date regarding initiatives related to the implementation of the tax reforms foreseen in the government agreement.