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Tax Reforms Hub Belgium

Latest federal and regional tax measures

Scroll down for a summary and analysis of the latest tax measures put forward by the federal and regional governments.

Overview of major corporate tax and indirect tax measures

On 9 October 2023, Belgium’s federal government reached an agreement regarding the Budget for 2024. The agreement contains several corporate tax measures, including proposed amendments to the controlled foreign company (CFC) regime and certain anti-avoidance measures, and a proposed tightening of the “Cayman tax”. In addition, the agreement puts forward several measures which will have a direct impact on the real estate sector, including for instance the removal of the reduced VAT rate on demolition and reconstruction for real estate developers.

These measures are expected to enter into force as from 1 January 2024, although this is not explicitly stated in notifications concerning the agreement.

  • 30 November 2023 | Further developments in strengthening the Belgian Cayman Tax | Deloitte Legal
  • 18 October 2023 | Budget 2024: tightening the Belgan Cayman tax ? | Deloitte Legal
Federal Government fails to find an agreement

The Federal Government failed to find an agreement on a "Broad Tax Reform". 

As a result, no major tax reform is expected during the remaining term of the current Government coalition. Federal elections are scheduled to take place in June 2024.
It is however expected that some of the measures in the proposal will, at some point in time, materialize. For instance, the introduction of mandatory B2B e-invoicing and transactional reporting remains highly likely, especially given the intentions previously expressed by the Ministry of Finance, and in the broader context of the European Union’s VAT in the Digital Age proposals.

Overview of most important tax, energy and social measures

The Program Law of 26 December 2022 implements most of the tax measures that were put forward by the Federal Government as part of the Federal Budget Agreement for 2023/2024.

The most important measures in this Program Law relate to:

Direct tax measures: (1) Temporary “Belgian minimum tax”; (2) Notional interest deduction; (3) Non-deductibility of financial sector levies; (4) Foreign tax credit for royalties; (5) Author’s rights; (6) Reduction of tax burden on labour; (7) Tax reduction for long-term savings

Energy measures: (1) Temporary excess profits tax; (2) Temporary solidarity contribution for fossil fuel companies; (3) Indirect taxes and excise duties on gas and electricity.

Social (security) contributions: (1) Employers’ social security contributions and indexation; (2) Indexation of company contribution.

Major changes in tax procedure

The Law of 20 November 2022 containing miscellaneous tax and financial provisions introduces several important changes in the tax procedure: (1) Extension in specific cases of investigation and assessment periods; (2) Extension of the objection and retention periods; (3) Penalty payment in case of tax investigation obstruction.

Significant amendments to partial wage tax exemption regimes

The major tax measures included in the Law on the reduction of labour costs concern: (1) a reduction of the special social security contribution; (2) amendments to the wage tax exemption regimes; (3) a new tax on boarding aircrafts; and (4) an increase of excise duties on tobacco. 

Law of 21 January 2022 on Miscellaneous Tax Provisions

Overview of major corporate and individual tax provisions

The Law of 21 January 2022 on Miscellaneous Tax Provisions includes various new tax measures.

Some of the most eye-catching ones relate to: (1) Fee reporting obligations; (2) Recharged costs; (3) Charging stations for electric vehicles; (4) Foreign losses.

Program Law | December 2021

New tax regime for inbound taxpayers and inbound researchers

As part of the federal 2021 budget agreement, the Belgian government introduced a new tax regime for “inbound taxpayers and inbound researchers”, replacing the previous “special tax status for foreign executives” as from 1 January 2022. The new regime is embedded in the Program Law of 27 December 2021.

Other measures put forward by this Program Law include (inter alia):

Income tax measures: (1) Changes to the tax benefits for sportspersons and sports clubs; (2) Changes to the tax regime of regulated real estate companies (GVV / SIR); (3) Non-deductibility of amicable settlement and regularization levies; (4) Tax reduction for day care; (5) Changes to the tax shelter regime for start-ups and scale-ups; (6) Increase of tax beneficial overtime with overtime premium in construction industry; (7) Extension of the validity of meal and eco vouchers.

Indirect tax measures: (1) VAT: changes to the VAT treatment of the supply of furnished housing; (2) Excise duties: changes for professional diesel and energy. 

Greening Mobility in Belgium | November 2021

New tax regime for company cars

As part of the Federal Government’s plans to reduce the CO2 emission of cars, a new tax regime for company cars has been enacted. The bill also extends the scope of the mobility budget regime, to encompass other sustainable modes of transport and additional types of cost.

Belgian Official Gazette Dutch | French // Parliamentary Documents Dutch | French

Tax Policy Note | November 2021

A glimpse into the Government’s tax policy ambitions and objectives for the coming year(s)

For those who want to get an idea of the tax policy priorities of the Federal Government, the Finance Minister’s Policy Note published on the Belgian Chamber’s website in November is mandatory reading. In this overview, we will focus on the most relevant tax ambitions and objectives in the Policy Note for tax practitioners dealing with corporate tax, individual tax, VAT, international tax or private wealth.  

New VAT rules for e-commerce applicable as of 1 July 2021

The goal of the EU VAT e-commerce package is to simplify cross-border B2C trade in the EU, ease the burden on businesses, reduce the administrative costs of VAT compliance and ensure that VAT is correctly charged on such sales. EU businesses will be able to compete on an equal footing with non-EU businesses that charge VAT.

The Mobility Budget, a second alternative to the company car

The Federal Government set itself a very ambitious goal to create a shift in mobility behaviour by providing an alternative to the current company car schemes, with the aim for such alternative to be cost neutral for all parties involved.

Belgian Official Gazette (Dutch | French) // Parliamentary Documents (Dutch | French)

The Mobility Allowance, an alternative to the company car

The Law introducing a mobility allowance puts forward a favourable tax regime for employees willing to trade in their company car for a monthly cash amount ("Cash for Car"). The Law addresses a broad scope of aspects, including personal income tax, social security, labour law and corporate tax.

Belgian Official Gazette Dutch | French // Parliamentary Documents Dutch | French

Optional VAT on immovable rent

The Belgian government has decided to introduce the option to subject immovable rent to VAT for projects as of 1 October 2018, adding a valuable alternative to exploit real estate in Belgium. The objective of the new regime is to provide companies flexibility in how they exploit their real estate, allowing landlords to deduct VAT on their investments.

How will the option to subject immovable rent to VAT impact businesses? Which is the best approach to a company's needs?

VAT on immovable rent: draft bill passed in Chamber of Representatives Commission on Finance (1 October 2018)

Optional VAT on immovable letting: draft bill to be submitted to Parliament (1 August 2018)

Belgian State Gazette Dutch | French // Parliamentary Documents Dutch | French

A story of give and take

Key measures in the 2017 corporate tax reform (Dutch | French) include a general rate reduction for all companies, a number of incentives to promote investment, and an important set of compensatory measures to keep the rate reduction budget neutral. Various repair changes were implemented, mainly by means of the law dd. 30 July 2018 (Dutch | French) (published in the Official State Journal on 10 August 2018).

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