• The reform will increase the net wages of everyone who works from 1 January 2027, with a focus on wages below the median. Net wages will increase during the legislature to lead to a difference between active and inactive of at least EUR 500. This will be achieved primarily thanks to:
  • An increase of the tax-free allowance for professionally active individuals.
  • Reduction of the Special Social Security Contribution and reinforcement of the work bonus (werkbonus/bonus à l’emploi). The gross salary should be equal to the net salary for persons earning minimum wages.
    A new deduction for (individual) entrepreneurs is introduced as of 2027.
  • Retired persons who continue working after either a career of 45 years or after the legal age of retirement will be subject to a final withholding tax of 33% (if more beneficial than the current progressive tax rate).

• The tax reform should once again make it more interesting to reward personnel in cash, rather than in benefits in kind. The existing collective bonus systems (CBA 90, profit premium, etc.) will be simplified and harmonized. This harmonization should not lead to an increase of the tax burden for the employer nor the employee.
• The tax-free sum for children at charge will be equal for each child (budget neutral measure). The increased tax-free sum will only apply for parents who are really single.

Objective: the reform aims at rendering our economy resilient, innovative, and sustainable, so that Belgium is not only competitive compared to other countries but stands out compared to these. This will be realized through cost reductions for enterprises and the stimulation of innovation.

Improving the competitiveness of the Belgian economy

• Broad envelope to address in a structural way competitive handicaps of the Belgian economy, primarily via a reduction of energy costs, a reduction of salary costs for low and average salaries and the introduction of a wage ceiling for employer social security contributions (as of the wage level of the prime minister). Measures to reduce cross-border purchases will also be adopted.

Attracting (new) investments

• Improvement of the tax regime for in-bound taxpayers to attract and retain international talent to Belgium: increase of the tax-free allowance from 30% to 35%, abolishment of the ceiling of EUR 90,000 and reduction of the minimum remuneration from EUR 75,000 to EUR 70,000.
• More attractive, flexible, and administratively simpler system of fiscal consolidation by extending the regime to indirect participations, not excluding new companies anymore and allowing the deduction of the Dividend Received Deduction (RDT/DBI) from the group contribution.
• The investment deductions can be carried forward without limits.
• To increase the purchasing power, social partners will, as soon as possible, increase the maximum employer’s contribution for meal vouchers by two times EUR 2 during the legislature. The tax-deductibility for employers will be amended accordingly. The possibilities of use of meal vouchers will be increased. Other forms of cheques (eco-cheques, culture cheques) will be gradually abolished, in consultation with the social partners.
• Accelerated depreciation of certain investments, e.g. in research and development, defense and energy transition. For large enterprises, it will consist in temporary regime allowing a 40% tax depreciation of the acquisition value during the first year. For SME’s, degressive depreciations will be possible again.
• The ‘taxation of foreign investments’ unit is turned into an 'investments' unit for Belgian and foreign enterprises investing in Belgium.
• Innovative companies in the field of maritime transport with sufficient substance must be able to continue to benefit from the tonnage tax system. including for multi-purpose ships. The regime is improved and simplified. Proactive role to be played by Belgium to negotiate international agreements to create an international playing field from the point of view of taxation and carbon emissions.

Stimulation of innovation

• Regarding the investment deduction for R&D, the regional attest requirement is abolished.
• An agreement will be concluded between Belspo and the tax authorities, with clear modalities of collaboration, guaranteeing the loyalty between both administrations and ensuring legal certainty for taxpayers.
• Possibility of recognition as a "research center" for enterprises realizing structural R&D, triggering long term certainty.

Objective: the government aims at supporting and strengthening the self-employed status, and provide for a better social protection, including illness coverage and well-being protection.

• Abolition of a series of smaller taxes and duties and administrative formalities.
• As of 2025, the tax on bank postings and the tax on premiums for self-employed pension contracts are abolished. As of 2026, smaller federal registration duties and other taxes are abolished.
• The form 270 MLH will be abolished, and a less burdensome alternative will be developed considering information readily available to tax authorities.
• The daily receipt book, the diverse VAT registers will be amended, simplified or abolished to the extent possible. To do so, existing possibilities of audit and information available to tax authorities will be considered. Other administrative formalities like, for example, the clients list will be abolished.
• Simplification of the rules regarding transfer pricing documentation, with a focus on SME’s, which will be limited to the essentials.
• The possibility of electronic labelling will be introduced to reduce production costs in Belgium. An ITC environment will be provided for publication to the official journal which can be done online thanks to a clear and accessible form.
• A new deduction for self-employed is enacted, applicable to self-employed in either a main or secondary occupation, a first bracket of the (net) income (after deduction of tax losses and deduction of professional expenses) can be deducted. This amount will be increased as of 2029.
• The different regimes of the 2nd pillar for self-employed will be harmonized and simplified. The 80%-rule will be reviewed.
• The rules allowing self-employed individuals to establish their own pension will be relaxed. Increase of the maximum contribution percentage of the Supplementary Pension for the Self-Employed (VAPZ/PCLI) from 8.17% to 8.5% as of 2026. The maximum contribution rate of the social VAPZ/PCLI will correspondingly be increased.
• Better recognition of the status of self-employed in a secondary occupation via a revision of their status (alignment with the self-employed in a main occupation). They will be allowed to contribute to a VAPZ/PCLI. Additionally, fight against improper use of self-employed status.
• For individuals earning “bénéfices/winsten” or “profits/baten”, abolition of the tax increase in the event of insufficient tax prepayments (as of 2026) and reinforcement of the bonification. Introduction of a 5th prepayment period (by 20 February N+1).
• Adjustments to the status of student-entrepreneur.
• Extension of the exemption of social security contributions for self-employed women after pregnancy to two quarters.
• Review of how periods of “overbruggingsrecht/droit passerelle” can open rights to pension.
• Adjustment of the yearly contribution of companies (“vennootschapsbijdrage/cotisation à charge des sociétés”), to be based on the total of the balance sheet.
• The social security contributions regulation for self-employed workers who wish to continue working after the legal retirement age and who have not yet taken their legal pension, will be adjusted so that they automatically continue to accrue pension rights if they continue to pay the contributions.
• Harmonization of the taxation upon withdrawal of an Individual Pension Capital (IPT/EIP) before the retirement age with the other pension systems.

• Amendment of legislation on the UBO register to reduce administrative burden.
• Specific provisions regarding digital counters.
• Investigate how the current exemptions from withholding tax on dividend and interest income can be simplified.
• Mandatory use of e-Box in business context foreseen for 2026.

Objective: financial investments are currently subject to various tax regimes. Investors should make investment decisions based on economic considerations, without disproportionate impact of tax regulation on these decisions. These tax regimes will be aligned where necessary and rendered simpler and more transparent for the investors.

• Existing tax reductions on investment income will be simplified. The increased individual pension saving will be integrated in the original pension saving in a budgetary neutral way.
• In the event of a negative judgement from the CJEU regarding the exemption of income from (Belgian) savings deposits, the Minister of Finance will submit a proposal within three months in which current reductions and exemptions are harmonized.
• A system similar to the Cooreman-Declercq one will be introduced to stimulate investments by individual savers in the economy. This system will be bundled with the existing tax reductions for starting companies and growth companies. Abuses will be tackled.
• Ensure legal certainty for occasional/miscellaneous income (article 90, 1° ITC) by introducing an exemption for a maximum amount of EUR 2,000 . This does not impact the non-taxation of income that does not fall under article 90, 1° ITC (i.e. tax-free gains).
• Modernization and simplification of the stock exchange tax to ensure a level playing field between various types of investment (financial instruments, companies and funds). The provision for funds of funds will be revised and clarified. Accounting and administrative obligations will be reduced. Reduction of compliance obligations for IPO’s.
• Relaxation of the legislation on private privak / pricaf, to reinforce venture capital.

Objective: the tax reform will uphold the opportunities that the climate challenge offers for our enterprises and help all households to render the transition that is required affordable.

• The limitations to the carry-forward of the investment deduction will be abolished. The investment deduction will be simplified and rendered more accessible in particular for investments in the energy transition. The restriction related to the existence of a financial support from European authorities (environmental list) will be abolished. The rates of deduction for investments on the energy, mobility and environment lists will be harmonized at 40%.
• Tax authorities will publish an administrative circular regarding the VAT deduction rate for mixed use company bikes.
• Reduction of VAT rate for heat pumps from 21% to 6% for the upcoming 5 years.
• Expansion of the scope of the existing VAT regime for demolition and reconstruction (6% VAT rate) to delivery of immovable property, existing social benefits being maintained. The surface criterion will be limited to 175 m2 for deliveries. The government will elaborate a clear definition of renovation works and will investigate how to introduce of a sustainability condition in the future European VAT legislation, without additional administrative burden.
• Investigation of a support mechanism for social lease of electric vehicles, aimed at employees having income under a certain threshold.
• Conditions of access to the tax deduction for car sharing will be reviewed. Intention to abolish the limitation to enterprises formally organizing car sharing and providing a financial contribution.
• Progressive abolition of the premium for new vans using fossil fuels when sufficient alternatives at an affordable price will exist. Temporary increased deduction for electric vans and trucks to stimulate investments in these alternatives.
• Thorough greening of the Belgian maritime fleet by creating fair competition for bareboat charters. For payments in the frame of such bareboat charters, a movable withholding tax exemption will be foreseen, in line with international standards at OECD level. The withholding tax exemption will be subject to conditions guaranteeing the greening of the fleet and the absence of tax optimization in the event of payments to related enterprises. Upon the implementation of this provision, European state aid legislation will be complied with while keeping in mind the objective to create conditions of fair competition.

Objective: the government strives for an efficient, fair, and simpler income tax environment. The current complexity of the income tax system often constitutes a challenge, primarily for SME’s.

The corporate income tax regime is simplified, and its predictability is improved. The government aims for an individual income tax system which is simpler to understand, so that taxpayers can more easily comply with their obligations without unnecessary complications.

• The government will review the possibility to introduce an optional simplified system of disallowed expenses.
• Simplification of the corporate tax system through an abolition or simplification of various exceptions, exemptions, … (abolition of the exemption for social liabilities, private PC plan and exemption of the capital gains on company vehicles). No impact anymore of the signature of a tax shelter agreement on the increase due to insufficient prepayments.
• The rules regarding the tax-deductibility of car costs will be simplified.
• As an electric company car is not an option for everyone, a longer transitional period is provided for the tax deductibility of costs related to hybrid vehicles.
• Continuation of the maximum deduction rate for hybrids at 75% until the end of 2027, followed by a decrease to 65% in 2028 and 57.5% in 2029 (simultaneously with the decrease for electric vehicles). These deduction rates apply for the entire duration of the vehicle's use by the same owner/lessee. The fuel costs of hybrids will remain 50% deductible until the end of 2027. The electric consumption costs of hybrids will have the same deductibility as those for electric models.
• An exception to this limited deductibility for hybrid cars with emissions of up to 50 grams/km will be introduced. If the percentage according to the deduction formula is higher than 75%, the higher percentage may be applied until the end of 2027.
• The mobility budget will be amended and will become a mobility budget for everyone. It will start from the principle of a putting at disposal a budget which can be spent to all types of transportation basis on their actual value. The new regime will replace the current interventions by the employer in the commuting costs. The new regime will have a tax friendly character. Grandfathering rules will be foreseen. It will be offered systematically as a possibility to employees who are entitled to a company car.
• Abolition of small reductions, exceptions and exemptions:
  • tax reduction in the context of investments in development funds for microfinancing.
  • tax reduction for domestic servants.
  • tax exemption for additional staff with a low wage and for additional staff for export and total quality management.
  • increased deduction of professional expenses for local mandates.
  • tax reduction for adoption costs.
  • tax reduction for legal aid.
  • tax reduction for donations decreases from 45% to 30%.
  • increased allowance for long-distance travel.
  • PC-private plan.
  • tax reduction for capital losses incurred due to the complete distribution of the corporate assets of a private privak.
  • tax reduction for electric motorcycles, tricycles, and quadricycles.
  • increased cost deduction of the internship bonus wages (“stagebonusloon”).
  • exemption for commuting by car will not be indexed once.
• Increase of the minimum wage from EUR 45,000 to EUR 50,000 for company directors to benefit from the reduced corporate tax rate of 20% on the first EUR 100,000. This threshold will be indexed going forward.

• The possibility to pay the annual director’s remuneration) as a benefit in kind will be limited to maximum 20% of the yearly gross salary. Additional bonuses on top of the gross (fixed) remuneration are still possible.

• New framework for costs proper to the employer will be introduced.

• Development of legal framework for flexible rewards. Reducing the pressure on gross wages by limiting the gross salary sacrifices to 20% of the gross annual salary. Additional bonuses can still be granted on top of the (fixed) wages. Administrative simplicity will be ensured.

• All employees (incl. contractual workers of the public sector) should be entitled to a solid supplementary pension for which an employer contribution of at least 3% will be provided by 2035 at the latest.
• Sectors that do not yet meet the 3% requirement will make an extra priority effort for this in their sectoral agreements. To this end, we will consult with these sectors. The government will invite social partners to explore how supplementary pensions can be further strengthened.
• The government will investigate how to avoid that supplementary pension taken in the form of an annuity is being taxed in a less tax beneficial way compared to a pension capital.
• The 80%-limit will henceforth be calculated based on identifiable and updated parameters that take into account the career already completed, in analogy with the philosophy currently used for the Wijninckx-contribution.
• To prevent abnormal increases in salary (at the end of the career), an average salary over the last years of the career will be used. The parameters for calculating the new 80%-limit will be aligned with the information available in databases such as MyPension, MyCareer and the database of the tax authorities.
• Withdrawals from IPT/EIP capital to finance real estate investments are no longer allowed, except for the sole own home.
• There will be a higher solidarity contribution on pension capitals, with the increase only applying to the portion of the capital amount above the threshold of EUR 150,000.

• Abolition of the tax reduction for unemployment benefits.
• Abolition of the tax reduction for the highest pensions.
• The tax credit for children at charge is no longer indexed, to mitigate the cases where no taxes are paid and yet a tax refund is received.
• The government considers the increase of the tax reduction for childcare for active persons.
• Living wages remain tax-free but will need to be reported in the income tax return to make sure all income is taken into account.
• Reduction by 50% of the marital quotient for non-pensioners by 2029. A sufficiently long(er) term will apply for pensioners. The income limit for students to be considered at charge for tax purposes is doubled. The maximum amount of net income (‘nettobestaansmiddelen’) for all children (as already applicable for 2024) is fixed at EUR 12,000 for everyone. The maximum amount of net income (‘nettobestaansmiddelen’) for all children (as already applicable for 2024) is fixed at EUR 12,000 for everyone. Permanent increase of the threshold of number of working hours to 650.
• The tax-deductibility of alimony payments will progressively be reduced from 80% to 50%. Payments to non-EEA beneficiaries will no longer be tax deductible for the payer.
• New maximum amounts for tax purposes will be introduced. The non-indexation of tax expenditures (strict meaning) will be continued.

Objective: the government strives to use subsidies in a more focused way and leverage financial resources more efficiently.

• The plus plans are amended. For the first employee, a reduction of contributions by quarter (EUR 2,000) is provided. Application of a reduction of EUR 1,000 by quarter from the 2nd to the 5th employee for the first three years of employment.
• The government will review which fossil subsidies can be reduced and within which timeframe this phasing-out can be realized, and this without generating any negative impact on the economy, the purchasing power or the cost of doing business.
• In the framework of the Fit for 55 package, a new system of trading of CO2 emissions quotas (ETS2) will be implemented by the European legislator for specific sectors. The underlying funding is used to accompany the energy transition for citizens and enterprises.
• VAT for the installation of a boiler using fossil fuels will be increased from 6% to 21% in the event of a renovation (for dwellings older than 10 years).
• VAT on coal is increased from 12% to 21%.
• A tax shift is realized on energy products (electricity, gas, fuel …) so that it contributes to reaching climate objectives without increasing the average bill of households and enterprises. Tax shift to be realized after reviewing the impact of the introduction of ETS2.
• Harmonization of the flight tax for travel in and outside the EU to EUR 5.
• The possibility to introduce a kerosene tax is investigated. Active role to be played by Belgium in the revision of the Chicago Convention of 1944. Improvement of the international train connections between high-speed train (TGV/HST) nodes and Zaventem airport. An access to the train network will be provided for the airport of Charleroi.

• Application of the excise duties regime to alternative tobacco products next to classical ones.
• The system of white cash register will be applicable to the entire hospitality industry.
• This system will also be expanded to fraud sensitive parts of the retail sector. A tolerance will be provided for small scale activities. The nominal threshold of EUR 25,000 is maintained but its calculation methodology will be amended. Improvement of the reliability of white registers. Support will be foreseen to facilitate these changes.
• The (direct and indirect) tax treatment of food and non-food (except specific categories like alcohol) donations to not-for-profit organizations is reviewed. The 15 days rule is in well-defined situations replaced by part of the lifetime of the food product.
• The price of the consumer basket is reduced, and measures are taken to reduce cross-border purchases. Reduction of the packaging tax for products where it is largely higher than in neighboring countries (e.g. water and reusable packaging). Excise duties on sugarless drinks, tea and coffee are abolished.
• A competitive advantage is preserved for professional diesel fuel which is sufficiently important compared to France and other neighboring countries.
• The government will investigate which other excise duties can be reduced to fight against cross-border purchases while respecting other objectives of the government agreement.

Objective: closely collaborating with European and international partners to strive for a greener taxation to accelerate the transition to a low-carbon economy and at the same time creating a level playing field for enterprises in the whole of Europa. The Government will also engage itself to increase European cooperation to address cross-border tax evasion.

• Implementation of the international agreements on a digital tax. Unilateral introduction from [2027] of a digital tax in the absence of an agreement at European or international level. A level playing field between Belgian and foreign enterprises active on the Belgian market will be ensured.
• Belgium will fully cooperate with the OECD initiatives for a fairer taxation where unanimity exists within the EU and OECD. It will consider both the competitivity of its enterprises and fair taxation before accepting any proposal.

• The government will do its utmost best to guarantee the legal certainty and stability of the application of existing partial wage tax exemptions. For shift and night work, the government will provide a system that guarantees the fundamentals and the benefit after the temporary arrangement ends. It will be checked if changes are required in view of possible changes to the provisions related to night work. An evaluation of the efficiency and output of all partial wage tax exemptions will be realized.
• One point of contact per taxpayer for all tax inspections and/or ongoing disputes or questions, easily reachable and available to meet.
• Mandatory publication by the tax authorities of all case law in which they are involved.
• Simpler and more streamlined tax audits through standard reporting.
• Reinforcement of legal certainty through a commitment to publish administrative circulars and amend administrative commentaries shortly after the publication of new legislation. Commitment of the government not to enact retroactive legislation and towards a more thematic tax legislation.
• Set up of a working group in charge of redrafting the income tax code (without substantive changes), rendering the current set of rules simpler and more transparent.
• Restoring of the level playing field between the taxpayer and the tax authorities through a taxpayer’s charter providing a harmonization of statutes of limitation, the right to a direct and personal contact with tax authorities, the right to mistakes, to privacy and the inviolability of the home, as well as a limitation of the duration of tax audits and an efficient process to manage complaints related to serious internal dysfunctions.
• Relaunch of “horizontal supervision” and granting of certain benefits for participating companies. Account management will be implemented for large enterprises.
• Strengthening of the Ruling Commission, its autonomy of decision-making being preserved. Evaluation of its current functioning, including the nomination process of College members. Improvement of accessibility for SMEs and individuals and special attention to be given to major files impacting investments and employment in Belgium.
• Evaluation of the functioning of the local tax offices to allow individuals and SMEs to obtain faster answers to simple questions.
• Additionally, evaluation of the mediation service (incl. nominations of the College). To reduce the backlog in tax litigation cases before Belgian courts, the mediation service is transformed into an arbitration service. Access to this service will only be possible after the administrative procedure. Processes will be implemented to prevent dilatory proceedings and arbitrary taxations. Independence and impartiality of tax arbitrators will be guaranteed. The losing side will bear the entirety of the costs of the arbitration.
• Clarification and qualitative improvements to the partial wage tax exemption for researchers to guarantee a maximal legal certainty, efficiency, budget management and stability. The scope of the partial wage tax exemption for universities, “hogescholen/écoles supérieures”, university hospitals and funds for scientific research is amended. Clarification of the scope of application of the provision for recognized scientific institutions by providing objective criteria and transparent rules.
• For legal entity tax purposes (RPB/IPM), possibility to have a taxable period deviating from the calendar year.
• Further extension of the Belgian network of double tax conventions, specifically for emerging economies, and prompt ratification thereof.
• Introduction of a simplified mandate and introduction of a single mandate for professionals (incl. lawyers), required for introduction of e-Box.
• Better spread of tax deadlines.
• Stable and transparent legal framework for the gaming and betting sector.
• The legislation regarding patrimonial documentation will be coordinated in a single code, modern and transparent increasing legal certainty.
• Amendments to the system of lottery introducing receipts to reduce tax fraud.
• Introduction of a clear legal system for assignment allowances of officials sent on mission.
• Revision of the sanction policy during tax audits, both in direct and indirect tax matters.
• The cash for tax rule will only apply to repeat violations triggering at least a 10% tax increase and will not apply to violations in good faith or administrative oversights. The compensation with the current year loss will become possible (but not with tax losses carried forward from previous years).
• Revision of tax penalty policies in income tax and VAT. Absence of sanction in the event of a first infraction in good faith.
• The principle of the protection of legitimate expectations is formalized in the law, implying y that no penalization occurs when a taxpayer takes a filing position that was already subject of a tax audit without adjustment.
• The VAT sanction policy will be modernized and will e.g. consider the absence of financial damage for the treasury as an attenuating circumstance.
• The opportunity to provide an exemption of sanctions in the event of an “objectively defendable point of view” in line with the Dutch legislation will be reviewed.
• To improve the tax technical quality of existing and future tax legislations and evaluate in a systematic way their economic, social and environmental impacts, the government reviews the role and composition of the high council of finance (HRF/CSF) section taxation and parafiscal levies. On the one hand, the nomination procedure is reviewed. On the other hand, its missions are amended to allow an evaluation of existing and future tax or parafiscal legislations.

Objective: combatting tax fraud will be an absolute priority for the government.

• Strengthening of the tax administration’s control capacity and specialized knowledge. Hiring of 300 persons with a focus on fight against tax fraud (special tax inspection, social fraud, judicial police, justice …).
• Increased cooperation between tax authorities and other relevant authorities (justice, police ...).
• Acceleration of handling of tax controversy files, within a reasonable timescale. This includes an increased use of the mediation procedure by tax authorities as well as the review of the possibility to assign legal cases to courts with less workload.
• New policy regarding tax penalties.
• Tax declaration, audit and recovery are improved. The feasibility and opportunity of a single tax balance including all sums due to a public entity, including taxes. Better recovery of taxes due and better control of conditions of grant of social benefits thanks to a better exchange of information with other regional and foreign authorities.
• Clear legal framework for the use of unlawfully obtained probative data.
• Harmonization of investigation and assessment periods and penalties applicable to several types of taxes, providing a level playing field between tax authorities and taxpayers:
  • The statute of limitation (investigation and assessment) in tax matters remains 3 years and is changed to 4 years for complex and semi-complex tax returns. To be calculated as of the first day of the tax year.
  • In the event of fraud, extended 7 years statute of limitation (8 for complex and semi-complex tax returns) as of the first day of the tax year
• For legislations based on lists of tax havens, improvement of legal certainty by providing that these legislations are based on the existing list per January 1 of the taxable period and applicable for the entire taxable period.

• The procedure to access banking information will be made more efficient for both tax authorities and financial institutions.

• Leveraging Data Mining and Risk Detection. Inclusion of crypto accounts, online gambling accounts (> EUR 10,000) and foreign accounts in the Central Contact Point of the National Bank.

• Mandatory publication of annual accounts of ASBL/VSW’s and foundations with the ‘balanscentrale/centrale des bilans’ replacing the obligation to deposit with the court. Administrative costs for publication abolished.

• Introduction of near "real-time invoice reporting" as from 2028 for transactions between vat taxpayers and transactions for which a registered cash register is used. Extra support will be provided for small businesses and self-employed.

• Increased efforts to conclude agreements with other countries on the automatic exchange of information, specifically with emerging economies.

• The government will support Regions willing to tackle share deals with respect to real estate companies.

• Abuse of private foundations will be addressed by amending the federal legislation defining what is a selfless (‘belangloze’/’désintéressé’) objective and by evaluating the sanction mechanism. Notaries will also be held accountable. In cases of improper use of a foundation, the tax authorities will have the possibility to request dissolution of the foundation. Improvement of the exchange of information and cooperation between the different services in charge of tax audits.

• Cooperation agreements will be used to improve the exchange of information and cooperation between the different services in charge of auditing taxpayers.

• The application of income tax to the not-for-profit sector will be amended in the light of amendments to the Code of Companies and Associations.
• The system of enforcement of penalties via court (‘dwangsom’/’contrainte’) when a taxpayer willingly hinders a tax visitation is replaced by a minimum taxable base.

•  A cooperation agreement is concluded between the federal state and the regions, allowing the communication of the individual tax returns of the last three years to the competent region in the event of death.

• The FASTER directive will be transposed.

• In alignment with regions, a permanent tax regularization process, stricter [than the previous ones], is implemented with envisaged rates of 30% (non-time-barred capital) and 45% (time-barred capital), except for taxpayers who can demonstrate that they are acting in good faith.

Objective: customs processes must be faster, simpler, and digital to reinforce the competitiveness of our harbors and logistic centers.

• Better cooperation between customs authorities and other public instances.
• Facilitating requests of binding tariff information with customs authorities.
• Customs processes: faster, simpler, and further automation and digitalization.
• Improvement of the status of Authorized Economic Operator (AEO).
• A new (more transparent and simpler) customs and excises Code will be worked on.
• The excise legislation will be codified and modernized in a coherent Excise Duties Code.
• Increased collaboration between customs authorities and private partners.
• Leverage excise duties for a comprehensive and strong anti-tobacco policy.
• Professional diesel: maintain a competitive advantage compared to France and other neighboring countries.
• Consider decrease of other excise duties to counter cross-border purchases.
• Reduce the packaging tax for all products that are significantly more expensive than in neighboring countries.

The overall effort is financed as follows:

Primarily thanks to the impact of structural reforms, amongst others of the labor market and pensions, including feedback effects. This should represent 2/3 of the overall effort by the end of the legislature.

The rest is financed by discretionary measures which should not exceed 1/3 of the overall effort at the end of the legislature. This share (1/3) of the overall effort is itself spread between the management of the increase of expenses (for at least 2/3 of the amount) and a contribution of the ‘strongest shoulders’ and diverse income (for at most 1/3 of the amount).

This last contribution (strongest shoulders and diverse income) is, on top of income from the fight against social and tax fraud, financed by the following measures:

• Dividend Received Deduction:
  • The participation exemption becomes an exemption instead of a deduction (increase of the beginning situation of the reserves).
  • The condition of participation of 10% remains unchanged, while the alternative threshold of EUR 2,5M is increased to EUR 4M. The participation exemption and the exemption of capital gains on shares for corporate tax purposes is restricted by adding to the EUR 4M threshold the requirement that the participation qualifies by nature as a financial fixed asset. An exemption is provided for SMEs (article 2, §1, 4°/1 ITC), i.e., is only applicable to dividend distributions between large companies.
  • A 5% levy is introduced for capital gains on ‘SICAV RDT’/’DBI-BEVEK’upon exit. The imputation of withholding taxes for corporate tax purposes will only be possible provided that, during the income year of receipt of the distribution, the minimum remuneration is paid to the “bedrijfsleider/dirigeant d’entreprise”.
• Bank contributions: the total contribution of banks remains at the same level as in 2025. The objective of 1.8% is maintained for the guarantee fund. An investment strategy will be established for the fund of guarantee of deposits.

• The possibilities to tackle the avoidance of the tax on securities will be investigated, in line with the recommendations of the Court of Auditors.
• Solidarity contribution: introduction of a general tax of 10% on future capital gains realized on financial assets built as of the entry into force of the contribution. Historical capital gains are hence exempt.
  • Capital losses of the year will be tax-deductible, without possibility of carry forward of any excess.
  • Exemption of EUR 10K to keep small investors out of the scope of the new tax. This amount is indexed yearly.
  • In the event of substantial participation of at least 20%, EUR 1M will always be exempt. Furthermore, the following tax rates will apply:
    • A capital gain between EUR 1M and EUR 2,5M will be taxed at 1.25%.
    • A capital gain between EUR 2,5M and EUR 5M will be taxed at 2.5%.
    • A capital gain between EUR 5M and EUR 10M will be taxed at 5%.
    • A capital gain as of EUR 10M: will be taxed at 10%.
• Extinction of federal tax benefits related to housing, except for the primary household.

• Carried interest: a specific and competitive (compared to existing regime in neighboring countries) will be introduced to stimulate the activity of funds in Belgium. Maximum tax rate of 30%. No impact on existing plans.
• Harmonization of the VVPRbis and liquidation reserve regimes. Changes to the liquidation reserve:
  • Waiting period reduced from 5 to 3 years.
  • Dividend WHT increased from 5% to 6.5% from 1 January 2026 for newly created liquidation reserves. This means that the effective tax rate increases from 13.64% to 15%, in line with the VVPRbis effective tax rate.
  • Advanced distributions (within the 3-year period) will be subject to the standard 30% withholding tax.
• Exit tax: emigration of a legal person will be treated as a fictitious liquidation for tax purposes.

• The scope of the author’s rights tax regime is expanded to put an end to the discrimination between digital (digitale / numériques) professions (not qualifying according to tax authorities) and other professions. All copyright protected work under the Code of Economic Law (Book XI, Title 6) will qualify going forward.
  
• Reduction of fiscal administrative burden for frontier workers. Negotiations with neighboring countries to simplify the tax situation of these workers, in a neutral budgetary context.