Tax measures: Corporate Income Tax

Below you can find more detailed information on related topics to Tax measures: Corporate Income Tax.

Important side note: Only the topics that are highlighted in green have been formally approved by the government. All other topics are proposals and have not yet been formalized.
  1. General

    If dividends are received by Belgian companies, there is a risk of double taxation to the extent that these dividends were already subject to corporate tax at the distributing company and would be included in taxable income in Belgium. 

    To avoid this, a deduction for "dividend received income" was provided, the DRD.

    A company is only entitled to the DRD to the extent that it holds a participation in the capital of the distributing company of at least 10% or with an acquisition value of at least EUR 2,500,000 (participation condition).

    Moreover, it must keep these shares in full ownership for a period of at least 1 year from the date on which the shares were acquired (holding condition).

    Under current legislation, dividends received are deducted from the tax result remaining after the previous operations. 

  2. Government agreement

    The Government Agreement provided for various adaptations to the DRD regime. These included:

    • The DRD deduction would be transformed into a genuine exemption for dividends received by a company.
    • The shareholding threshold of 2.5 million euros would be raised to 4 million euros. This increase would also be coupled with a requirement that the shares have the nature of financial fixed assets. However, these changes would only apply to large companies and transactions between them.  
    • For DRD SICAVs, a 5% tax would be applied in the event of a capital gain. In addition, the possibility of deducting withholding tax from corporate income tax would only be possible if the company receiving the dividends paid out by the DRD SICAV granted a minimum remuneration to its director.
  1. Upcoming and implemented changes

    The law of 18 July 2025 does not include all the above adaptations.

    • a. DRD exemption
      The DRD deduction will be converted into an exemption. The law is silent on this point.
    • b. Holding threshold
      With regard to the holding requirement, the law maintains the current threshold of 2.5 million euros. There is no increase in the threshold to 4 million euros. The new requirement to account for financial assets is also introduced but this requirement will only apply for large companies, hence  “small companies” within the meaning of Article 2 of the Income Tax Code will be excepted.

      This condition of financial fixed assets will also apply to the exemption from withholding tax referred to in article 264/1 of the Income Tax Code (i.e. Tate & Lyle).
      These changes will take effect from the 2026 tax year for the DRD deduction and from July 1, 2025 for the withholding tax.

    • c. DBI-beveks 
      • For the so called “DBI-RDTBEVEK/SICAV” (a special investment company with variable share capital, a separate tax of 5% will be introduced, which will be levied on the capital gains realised on shares or units of investment companies and real estate companies that fall under the DBI/ RDT scheme. This therefore applies to BEVEKs, but also to all investment and real estate companies that fall under a different tax regime, such as foreign companies with a similar different regime in their national law. It should be noted that the distribution of dividends is not subject to this new levy.
      • Furthermore, from now on, the withholding tax can only be offset against corporation tax if the company receiving the dividends distributed by the DBIBEVEK/SICAV grants a minimum remuneration to its manager (see Article 215, paragraph 3, 4°BITC).
      • The DBI/ RDT deduction will be converted into a genuine exemption for dividends received by a company. No provision has yet been made for this in the law. The Explanatory Memorandum states that the DBI/RDT deduction will be converted into an exemption, without giving further details. It is specified, however, that this conversion will only be implemented in a later draft law.

    • d. Group contribution scheme and DBI / RDT deduction In order to bring the DBI / RDT scheme into line with the European Parent-Subsidiary Directive, the DBI / RDT deduction for the year will be allowed on the portion of the group contribution that exceeds the negative result determined before the group contribution was included in the tax base for the period in question. 

Small companies can enjoy a reduced rate of 20% on the first bracket of EUR 100,000, provided certain conditions are met. The part of the taxable base exceeding EUR 100,000 is taxed at the basic rate of 25%.

Thus, among other things, the company must grant a minimum remuneration of EUR 45,000 to at least one company director. If the remuneration is less than EUR 45,000, it must at least equal or exceed the company's taxable income .

The minimum remuneration requirement is increased to EUR 50,000 on an annual basis, henceforth indexable. Moreover, a maximum of 20% of the remuneration may still consist of benefits in kind.

No provision is currently included in the draft law of 3 July 2025.

VVPR bis regime/liquidation reserve

Dividends distributed by companies that are 'small' can, under certain conditions, benefit from a reduced withholding tax rate instead of the normal 30% rate. 
 
The favourable VVPR bis regime only applies to new shares issued as from 1 July 2013, either at the time of incorporation of the company or at the time of a capital increase. The shares must be fully paid up and registered. Subject to certain exceptions, the shares may not be transferred after contribution.

Provided all these conditions are met, the current VVPRbis scheme provided that dividends distributed by small companies could benefit from the following preferential rates:
-  20% if the distribution takes place after a three-year waiting period, provided that the contribution was made no later than 31 December 2025 (Law of 18 July 2025, Belgian Official Gazette, 29 July 2025);
-  15% if the dividend is distributed after four years or later.


As approved by the law of 30 May 2026:

The Programme Act of 30 May 2026 provides that the rate will be increased from 15%  to 18% for all distributions made as from the first day of the month following the month in which the Act is published in the Belgian Official Gazette, regardless of the date of the contribution. 

Small businesses also have the option of allocating their post-tax profits to a liquidation reserve. When this allocation is made, effective from the end of the financial year, a separate contribution of 10% is payable. 
Upon the subsequent distribution of this liquidation reserve, an additional withholding tax is payable, the rate of which is now determined as follows:
-   For reserves formed on or before 30 December 2025, the rate is 20%, 6.5% or 5% if the distribution takes place, respectively, within three years, between three and five years, or after five years; 
-   For reserves formed on or after 31 December 2025, the rate is 30% or 9.8% if the distribution takes place, respectively, before or after a period of three years has elapsed.

The liquidation reserve regime has now been amended to achieve greater tax harmonisation with the VVPRbis regime, both in terms of the minimum distribution period required to qualify for the reduced rate and in terms of the effective rate of 18%.

Finally, anti-abuse measures have been introduced, particularly in cases where a person takes up a similar role as a company director within three years of the liquidation.

The Programme Law of 30 May 2026 introduces, with effect from 1 January 2027, an adjustment factor applicable to the amount of withholding tax due by an employer on remuneration and which is not payable to the State. This adjustment factor aims to contain the cost of exemptions from payment of the withholding tax on professional income by offsetting the effects of inflation and the indexation of remuneration.

In practice, the percentage of the exemption will continue to be applied to eligible remuneration paid or awarded, and when declaring withholding tax, the adjustment factor will be applied to determine the amount that must ultimately be paid to the State.

The adjustment factor will be 97% for the year 2027, 93.35% for the year 2028, and 95.9% from 1 January 2029. 

Companies investing in investment companies can typically offset any withholding tax due on dividends in their corporate income tax return. From tax year 2026 (i.e. for each financial year ending on and from 31 December 2025), a condition will be added. If this condition is not met, an additional cost of 30% will arise on these dividends (including on dividends already received in 2025).  

What does this condition mean? 

The withholding tax on dividends from investments in, among others, DBI SICAVs, real estate investment companies, a regulated real estate company, etc. is no longer deductible from the corporation tax due if the dividend received exemption applies. 

Exception 

It is still possible to offset the withholding tax if the taxpayer grants the minimum remuneration to at least one director during the taxable period in which the income is obtained. This is the same minimum director's remuneration that small companies must grant in order to benefit from the reduced corporate income tax rate (20% on the first €100,000 of taxable profit). Currently, this amounts to €45,000 (unless the company's taxable income is lower, in which case it must be at least equal to this lower amount). The government announced that it will increase this amount to €50,000 and index it annually. 

It can therefore also be important for "large" companies to grant a minimum director's remuneration. 

Important: changes to the closing date of the financial year from 3 February 2025 that are not justified for reasons other than the avoidance of these provisions will have no effect on the application of this measure. 

Given that electric vehicles are not an option for everyone, a longer transition period is planned for hybrid vehicles.

However, this transition period only applies to personal income tax (see: ‘Tax measures: Personal income tax - BDO’).

Consequently, the rules on deductions for vehicle taxation, as defined in the law of 25 November 2021, remain applicable to corporate tax (for more details: ‘Green mobility: what are the changes in terms of taxation?’).


There will be the possibility of accelerated depreciation of certain investments, for example in research and development, defence and energy transition.  

For large companies, this is a temporary system whereby 40% of the acquisition value can be written off in the 1st year. 

For SMEs, there will again be the possibility of degressive depreciation.

The group contribution regime allows a profitable company to transfer (part of) its profits for tax purposes to a group company that realised a loss in the same assessment year. The transferred profit is referred to as 'the group contribution'. 

That group contribution may be deducted by the profit-making (transferring) company from its taxable result, while the loss-making (receiving) company includes the group contribution received in its taxable result. In this way, the profit-making company pays less corporate tax while the loss-making company carries forward no or fewer losses to a subsequent financial year.

This regime can only be applied provided some rather strict conditions are met. Among other things, the transferring company and the receiving company must be at least 90% linked for an uninterrupted period of five years. On the part of the receiving company, it is not possible to offset the group contribution included in the tax base with tax deductions.

The government will make the group contribution system more attractive, flexible and administratively simpler, by allowing both direct and indirect shareholdings, no longer excluding new companies, and allowing dividend received deduction (DRD) on profits arising from a group contribution.

Less restrictions regarding the investment deduction 

  • The investment deduction becomes transferable without restriction. The deduction restriction for the transfer of the basic deduction is abolished. Under the current scheme, small enterprises that are unable to use the deduction accumulated in year N are obliged to use it in the following year (N+1). 
  • Furthermore, the percentages of 30% for large enterprises and 40% for small enterprises will be harmonised to a uniform percentage of 40% for all enterprises with regard to the categories of increased investment deduction. 
  • The regional certificate requirement for the investment deduction for research and development is abolished.  
  • With regard to the technological deduction (former investment deduction for patents and R&D), taxpayers again have to choose between the application of this deduction and the tax credit for research and development (R&D tax credit). 
    For other investments, the irrevocable choice between the tax credit or the investment deduction remains applicable.  
  • Finally, the prohibition on cumulating the thematic increased deduction with regional state aid is skipped.  

These changes will coincide with the entry into force of the law on 1 January 2025 in order to prevent ‘the coexistence of two different systems based on early adjustments to a quasi-new system’. The harmonization of the 40% rate will take effect from the 2027 tax year. 

If certain conditions are met, meal vouchers are exempt from personal income tax on the part of the beneficiary and the employer's contribution of EUR 2 per cheque is tax deductible.

Thus, the employer's contribution to the amount of the meal voucher may not exceed EUR 6.91 per meal voucher. The beneficiaries' contribution must be at least EUR 1.09.

Both the statutory maximum contribution of EUR 6.91 and the deductibility of the employer's contribution will be increased by two times EUR 2 in the coming legislature. 

Also, the spending option of the meal voucher will be expanded. 

The other existing vouchers (eco vouchers, culture vouchers, etc.) will be phased out.

In order for contributions to supplementary pensions to be tax deductible for the company, the statutory pension and the supplementary (non-statutory) pension together may not exceed 80% of the last year's normal gross remuneration. 

If this limit is exceeded, the company cannot deduct the part of the contribution exceeding the 80% rule as professional expenses.

This 80% rule would now be more clearly defined. Moreover, it would no longer be possible to receive an advance on a supplementary pension to finance real estate investments, except for the sole owner-occupied dwelling.

  1. General

    When a company transfers its principal place of business or its seat of management or administration abroad, this transfer is treated as a liquidation for tax purposes. 

    As a result, corporate income tax is due on unrealised capital gains and tax-exempt reserves, unless a Belgian establishment remains after the head office transfer, to which these items are attributed.

    Until now, and this has been confirmed several times by the ruling commission, this fiction of liquidation has not been considered to have any consequences for the shareholders of the company whose registered office is transferred. Strictly speaking, there is no allocation or payment of income from movable assets to shareholders, so in principle, no withholding tax is due. 

  2. Government agreement

    In this respect, the Government Agreement states that the emigration of a legal entity will be treated for tax purposes as a fictitious liquidation of the legal entity, with the application of withholding tax. Thus, the fiction of liquidation would henceforth also apply to shareholders.

  1. Changes introduced by the  Law of 18 July, 2025
    The Law of 18 July, 2025 supplements the notion of dividend to provide that a dividend is deemed to be attributed to the shareholders of a company in the event of transfer of its registered office or when it takes part in restructuring operations (merger, demerger, etc.) resulting in assets being transferred abroad.

    This notional dividend corresponds to the distributed dividend referred to in article 209 of the Income Tax Code, limited in proportion to the shares held. This dividend will constitute income from movable property taxable at 30%, unless it can be exempted by application of the liquidation reserve regime. For corporate shareholders, the definitely taxed income deduction will apply to the notional dividend, where applicable.

    This change applies equally to shareholders subject to individual income tax, corporate income tax and legal entities income tax.

    However, if no dividend is actually paid, no withholding tax can be deducted from the dividend. It must therefore be included in the tax returns of the taxpayers concerned. To this end, companies transferring assets abroad as part of the above-mentioned operations will be required to draw up individual sheets (failing which they will be subject to the distinct contribution referred to in article 219 of the Income Tax Code).

    The law also stipulates that, to comply with European law, a staggered tax payment may be requested in the event of an asset transfer to another Member State.

    Lastly, to avoid double taxation when a dividend is actually paid by the company transferring the assets abroad, and when a capital gain is realized on the sale of these assets, an exemption is provided for shareholders.

    This new exit tax will apply to transactions taking place as of July 29, 2025.

The government will simplify transfer pricing documentation rules, especially for SMEs, and limit them to the essentials.

The government will abolish Annex No 270 MLH (an annex that the tenant of a professionally used property has to attach) as soon as possible.

Belgium will implement international agreements on a digital tax (pillar 1). That way, large digital multinationals will be taxable even if they have no physical presence in Belgium.

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