The Belgian government has presented an overview of its tax reforms to the parliament on 24 April 2025.
This follows after Belgium’s five political parties agreed on a coalition government program on 31 January 2025, outlining various tax reforms.
The key tax measures are summarised below.
Participation exemption
The required shareholding remains 10%, and the investment threshold will also remain unchanged is EUR 2.5 million. The coalition government program proposed increasing the minimum investment threshold from EUR 2.5 million to EUR 4 million. To qualify for the exemption, the investment must be a fixed financial asset, except for small companies.
Capital gains tax
The government plans to implement a 5% tax on capital gains from shares sold by collective investment companies that qualify for the participation exemption.
Investment deduction
The government will remove the restriction on carrying forward unused investment deductions and align the rates for large and small companies at 40%.
Liquidation reserve
- The holding period for liquidation reserves will be reduced from 5 years to 3 years.
- Starting in 2026, the withholding tax rate on newly created liquidation reserves will rise from 5% to 6.5%.
- Existing liquidation reserves can be distributed after 3 years, subject to a 15% tax rate.
VAT rates
The government will extend the 6% VAT rate for demolishing and restructuring buildings to supplies. The VAT on fossil fuel boilers will rise from 6% to 21%, and on coal from 12% to 21%.
Exit tax
Under the current exit tax, companies that relocate to another country are treated as liquidated. The government will extend this tax to shareholders, who are treated as receiving a liquidation dividend.
Statute of limitation periods
The timeframes will be standardised to 3 years and 7 years in cases of fraud.
Embarkation Tax
The embarkation tax for long-haul flights will be set at EUR 5.
Penalties
The government plans to implement a rebuttable presumption of good faith for taxpayers facing their first infringement.
