Eased STRIT/STRIR Rules Strengthen Belgium’s Tax Attractiveness

As announced in the Easter Agreement and now officially enacted by the Law of 18 December 2025, amendments are being made to the ‘new’ special tax regime for inbound taxpayers (STRIT) and inbound researchers (STRIR). This regime, which came into force on 1 January 2022 to replace the tax status for foreign executives in place since 1983, aims to enhance Belgium's appeal to international companies.

The Law of 18 December 2025 introduces further easing of the regime, strengthening its competitiveness compared to similar regimes in neighboring countries.

The following changes are being implemented:

• The maximum percentage of the tax-free allowance is increased from 30% to 35% of the gross remuneration granted.
• The tax-free allowances are no longer capped at 90.000 EUR
• The minimum gross salary for the STRIT regime (i.e. gross salary before deduction of social security contributions but including holiday pay, year-end bonuses, benefits in kind, and bonuses—unless these are uncertain at the time of application) is reduced from EUR 75,000 to EUR 70,000 per calendar year.

Note that the last condition (i.e. salary condition) does not apply to researchers. However to be eligible for the STRIR the researchers have to hold a specific master degree (natural sciences, applied sciences, medical sciences, agricultural sciences and engineering) or have at least 10 years of relevant experience in these fields. 

The social security authorities confirmed in the past that the reimbursements under the STRIT/STRIR regime are free of social security. It is expected that amendments (i.e. increase of the maximum percentage to 35% and abolishing of the annual maximum amount) will not affect this exemption. 

These amendments will apply to remuneration paid or granted as from 1 January 2025. Therefore, the changes may also be applied to employees who are already benefiting from the special tax regime.

Employees who started working in Belgium between 1 January 2025 and the tenth day after the publication of this law in the Belgian Official Gazette, and whose salary was below 75,000 euros, may still apply to benefit from the special tax regime for incoming taxpayers under the condition that they meet all other requirements. The application must be submitted within three months, starting from the tenth day after the publication of this law in the Belgian Official Gazette. 

In the example below, the net salary has been determined with a cost for the employer for the employer of 135.000 EUR in the following scenarios:

• No application of the STRIT (= regular resident tax calculation)
• Application of the STRIT taking into account the rules prior to the enactment of the law of 18 December 2025
• Application of the STRIT under the new rules effective as of 1 January 2025

 

When calculating the net salary, it was assumed that the taxpayer is single, has no dependent children, and is a resident of Belgium. Raising the maximum percentage of the tax-free allowance to 35% positively affects the employee’s net income.

If you, as an employer, choose to apply the increased 35% expense allowance to employees already benefiting from the regime, and this requires an adjustment to the gross salary, we strongly recommend formalizing this change through an addendum to the employment contract.

With these adjustments, Belgium proactively strengthens its position in the global competition for talent and investment. By enhancing the STRIT/STRIR regime—through measures such as a higher expense allowance and a lower salary threshold—the tax framework becomes more competitive relative to neighboring countries. This is expected to support the attraction and retention of highly qualified foreign employees and researchers as of 1 January 2025.

Should you have any further questions about how these changes may impact your employees, please do not hesitate to contact Charlotte Lemahieu, Nicolas Stockmans or one of the other specialists of our IMS team.