Belgium's government has proposed doubling the securities account tax to 0.3% and raising dividend withholding rates to 18% for small companies, while also introducing higher flight taxes and insurance premiums starting in 2026.
Belgium’s government submitted an Omnibus Bill No. 56 1378/001 to parliament on 23 February 2026, proposing several tax amendments, including an increase in the annual tax on securities accounts and a higher dividend withholding tax rate for SMEs.
This bill outlines a series of legislative reforms and budgetary measures proposed by the Belgian government for the 2025–2026 period. Key fiscal changes include increased taxes on aviation and financial institutions, alongside revised excise duties on fuels to encourage decarbonisation and energy efficiency.
The key changes are as follows:
Annual securities account tax
The government proposes to double the rate of the annual tax on securities accounts from 0.15% to 0.3%. This new rate will apply to reference periods that end on or after the date the law is published in the Belgian Official Gazette.
Dividend withholding tax for SMEs
The proposed legislation adapts the tax rates for small companies utilising the liquidation reserve and VVPRbis regimes.
The VVPRbis regime permits small companies to apply a reduced dividend withholding tax rate on dividends linked to new registered shares issued for cash contributions from July 2013 onward, provided the required statutory holding period is met.
- Liquidation reserves: For distributions made after the mandatory three-year waiting period, the withholding tax rate will increase from 6.5% to 9.8%. This adjustment is intended to reach a total effective taxation of 18%, which includes the initial 10% distinct contribution paid when the reserve was created.
- Anti-abuse measure: A new provision targets “stop & go” situations; if a beneficiary receives a liquidation dividend and resumes the same or similar activities via another company within three years, the distribution will be reclassified as taxable investment income. This reclassification can be avoided if the taxpayer proves the actions were motivated by reasons other than tax avoidance.
- VVPRbis regime: For dividends distributed from the third accounting year onwards (or later) following a capital contribution or increase, the tax rate will rise from 15% to 18%.
The increased VVPRbis rate and the liquidation reserve anti-abuse measure take effect on the first day of the month following the law’s publication. A transitional measure maintains the 20% rate for certain reserves added on 31 December 2025, if they are paid out before the law officially enters into force.
Flights tax
The tax on boarding an aircraft is being progressively increased starting in 2027, primarily to meet budgetary needs rather than environmental goals.
- On 1 January 2027, the tax for destinations further than 500 km will increase from EUR 5 to EUR 10.
- For shorter flights (500 km or less), the current EUR 10 tax will rise to EUR 10.50 on 1 January 1, 2028, and to EUR 11 on 1 January 2029.
Business pre-levy exemption
The government aims to preserve the budgetary viability of these regimes, which have seen considerable growth due to wage increases and an expanded scope.
- Correction factor mechanism: To “freeze” the total fiscal cost of these exemptions at 2026 levels, a correction factor will be applied to the amount of professional pre-levy that is not transferred to the Treasury.
- Successive rates: The correction factors are set as follows:
- 97% for remuneration paid in 2027.
- 93.35% for remuneration paid in 2028.
- 95.9% for remuneration paid from 1 January 2029 onwards.
Insurance premium tax
The rate will increase from 9.25% to 9.6% for premiums due as from 1 April 2026. Anti-abuse rules will apply where a contract is cancelled and replaced with a very similar one shortly before the new rate takes effect to avoid the increase.
Annual tax on credit institutions
The legislation modifies both the tax base and the rates for credit institutions, effective from the 2027 tax year.
The tax rates are being adjusted upward (specifically, 0.15205 becomes 0.19286 and 0.20204 becomes 0.25626).
To encourage strategic and sustainable investments, particularly for SMEs, debts toward the European Investment Bank (EIB) are excluded from the tax base.
Debts toward Central Counterparties are also excluded. This corrects a technical reporting issue that unintentionally penalised banks for using CCPs, which are encouraged by European regulators to promote financial stability.
Excise duties
- Fossil fuels: Gradual increases in excise duties are planned for gasoline and diesel used as fuel starting 1 January 2027. Natural gas for non-professional heating will also see annual increases between 2026 and 2029.
- Electricity: Conversely, excise rates for non-professional electricity consumption will be gradually decreased over the same 2026-2029 period to encourage consumers to switch to electric alternatives. For protected residential customers, the rate is significantly reduced to EUR 1 per MWh.
Taxation of copyright and related rights
The government is limiting the 15% flat-rate expense deduction for copyright and related rights income to taxpayers holding a valid arts work certificate, excluding starter certificates. The measure aims to refocus the regime on professional artists and prevent its use by other professionals who can deduct expenses elsewhere. It applies to income paid or attributed from 1 January 2026.
