Draft program law submitted in Parliament

The draft program law (Dutch | French) has been submitted to Parliament and includes a set of tax measures that will affect individuals and businesses. These measures form part of the government’s broader budgetary and policy objectives and are intended to enter into force progressively, subject to parliamentary approval.

This summary provides an overview of the main tax provisions contained in the draft program law. The information below is based on the draft text as submitted and may therefore be subject to amendment during the legislative process.

VVPRbis and liquidation reserve

VVPRbis

Small companies can apply a reduced withholding tax rate under certain conditions on dividend distributions for contributions made in cash as from 1 July 2013. They could distribute dividends from the profit distribution of the third financial year following that of the contribution, at a 15% withholding tax rate.

This program law increases the reduced withholding tax rate for VVPRbis distributions from 15% to 18% for distributions as from the first day of the month following the publication of the law.

Until the first day of the month following the publication of the law in the Official Journal, the following withholding tax rates will apply for VVPRbis:

*Only for contributions or capital increases made no later than 31 December 2025.

As from the first day of the month following the publication of the law in the Official Journal, the following withholding tax rates will apply for VVPRbis:

*Only for contributions or capital increases made no later than 31 December 2025.

Liquidation reserves

The current rate of 6.5% - as applicable to distributions by small companies of liquidation reserves for which the 3-year waiting period has been respected - will be increased to 9.8%, to achieve a total effective tax rate of 18%.

After implementation of the program law, the following withholding tax rates will apply for liquidation reserves:

Liquidation reserves established in financial years ending on or before 30/12/2025:

Liquidation reserves established in financial years ending from 31/12/2025 onwards:

*Exception: 20% for dividends granted or allocated before the entry into force of the program law originating from liquidation reserves established on exactly 31 December 2025.

Any changes to the closing date of the financial year made on or after 24 November 2025 will be disregarded. 

Anti-abuse rules prevent companies from liquidating reserves tax-free and continuing the same activity under a new company.

Tax regime for copyright

Income from copyrights is considered movable income up to a (gross) amount of up to EUR 75,360 (amount valid for income year 2025). In addition, authors could benefit from an important cost lump sum on the income received. The balance was subject to a withholding tax of 15% which is due by the copyright debtor.

As of 1 January 2026, the lump sum cost deduction is no longer applicable, unless the taxpayer holds an official “arts work certificate” (a starters attestation is insufficient). Going forward, only actual professional expenses can be deducted by taxpayers not holding such certificate.

Partial wage tax exemption

A correction factor will be introduced to moderate the total fiscal cost of professional withholding tax exemptions.

During the period in which remunerations are paid or granted that qualify for the exemption, the current exemption rate can continue to be applied.

Following the second withholding tax return, a correction factor will be applied to the withholding tax not remitted as a result of the exemption, which determines the amount that must ultimately be paid to the Treasury. The correction factor reduces the amount of withholding tax exempted for salaries.

• For payments between 1 January 2027 and 31 December 2027: 97%,

• For payments between 1 January 2028 and 31 December 2028: 93.35%,

• For payments as from 1 January 2029: 95.9%.

Indirect taxes

Excise duties

The special excise duties on diesel and petrol used as motor fuel will change as from 1 January 2027.

The rate for natural gas used as heating fuel for non-professional use will increase in 2026, 2027, 2028, and 2029.

The excise duty applicable to electricity for non-professional use by consumers other than protected residential customers will be reduced.

The rate for gas oil used for heating will increase in 2026, 2027, 2028, and 2029.

To ensure administrative simplification, the rate for gas oil used as motor fuel for industrial and commercial purposes is aligned with the new rates for gas oil used for heating.

Miscellaneous duties and taxes

Increase air passenger tax

The program law of July 18, 2025, increased the rate of the embarkation tax to EUR 5 for flights of more than 500 kilometers, and kept the rate at EUR 10 for flights below 500 kilometers.

The new draft program law provides for a further, gradual increase:

Increase of the “banking tax”

The rate of the banking tax will increase as from assessment year 2027.

Credit institutions are liable for the tax on the average amount of their debts to clients prior to the tax year. The notion of 'debts to clients' is clarified by reference to the amount that, in accordance with the regulations of the National Bank of Belgium, must be reported in the context of territorial reporting on line 229 (column 05) in table 00.20 of Schedule A.

The tax base is adjusted to exclude debts owed to the European Investment Bank (EIB), addressing concerns that EIB debts increase tax burdens unfairly. A further adjustment concerns debts towards central counterparties (CCPs). Those are also excluded from the taxable base.

Increase of the annual insurance tax

The normal rate of the annual insurance tax increases from 9.25% to 9.6%, applicable to premiums due as from 1 April 2026.

The administration will verify whether the general anti-abuse provision, contained in Article 202 of the Code of Various Duties and Taxes, is applicable in cases of termination of an insurance contract before its expiry date and the conclusion of a new identical contract, covering the same risk, by the same policyholder with the same insurance company before the said expiry date, whereby the reduced rate could still be applied.

Increase of the annual tax on securities accounts

The rate doubles from 0.15% to 0.3% on securities accounts holding more than EUR 1 million. The increase will apply to reference periods ending after the law’s publication in the Official Journal.