Capital gains tax / Solidarity contribution

Agreement 30 June 2025

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Important side note: This proposal has not yet been laid down in a legal text, consequently no certainty can be given at this stage as to the correctness and/or completeness of the conditions.
The government reached an agreement on 30 June 2025 on the principle of a capital gains tax on financial fixed assets, the so-called ‘solidarity contribution’.

A distinction should be made between a general tax of 10% and capital gains realised following the disposal of a so-called substantial interest.
 
General taxation of a capital gain
  • A general tax of 10% is introduced on capital gains realised on financial assets, including crypto assets, albeit without retroactive effect and with exemption of historical capital (= capital gains accrued until 31 December 2025). Those selling their shares thereafter will have the choice of deducting the value of the shares on 31 December 2025 or the original purchase price from the sale price.
  • An exemption of 10,000 EUR per year (to be indexed annually) will be introduced, which will increase by EUR 1,000 annually if no capital gain is realised up to a maximum of 15,000 EUR
  • Pension savings and group insurance will be exempt from this capital gains tax.
  • It should be noted that capital losses on such assets would now be deductible, but only from this income category and without the possibility of carrying them forward to subsequent taxable periods.
Capital gains on the disposal of a substantial interest
In the case of a so-called substantial interest, a separate regime of capital gains tax will be introduced.

What are the conditions?
  • At least 20% holding at any time during 10 years prior to the transfer;
  • 'Historical capital gains’ will be exempted, i.e. capital gains accrued up to 31 December 2025 will be called historical. Those selling their shares thereafter will have the choice of deducting the value of the shares on 31 December 2025 or the original purchase price from the sale price.
  • There is an exemption on the first tranche of EUR 1,000,000
    Above EUR 1,000,000, graduated rates are applied:
    • Between EUR 1,000,000 and EUR 2,500,000: 1.25%
    • Between 2,500,000 EUR and 5,000,000 EUR: 2.25%
    • Between 5,000,000 EUR and 10,000,000 EUR: 5%
    • Above EUR 10,000,000: 10%
The calculation will be done per tranche.

The exemption EUR 1,000,000 will apply per five-year period to discourage stepped sales and will also apply per person and therefore cannot be bundled with family members.

Contact us for more information

Erwin Bouwmans
Erwin Bouwmans
Partner
erwin.boumans@bdo.be
Hubert Hellraeth
Hubert Hellraeth
Partner
hubert.hellraeth@bdo.be