A few months after the Arizona coalition reached a coalition agreement, the first fiscal plans are on the table. According to an article in De Tijd, which was given access to the draft text of the program law, we can expect a series of concrete fiscal measures that can be felt as early as this year. This program law will be submitted to parliament at the end of March and will include adjustments to deductions, regularization procedures and tax benefits.
Introducing a capital gains tax on shares and increasing the tax-free allowance are not yet part of this first package. These will not follow until 2026. Nevertheless, this law already contains ten tax measures that may be relevant to entrepreneurs, investors and property owners. We explain them below.
1. Higher threshold for FDI deduction
What is it about?
With the FDI Deduction (Definitively Taxed Income) are profit distributions From subsidiaries to the parent company tax-free if they were taxed at source at all.
What is the current legislation?
One of two conditions must be met:
1) The parent company must at least 10% of shares hold in the subsidiary.
2) The parent company must issue shares with a acquisition value of at least 2.5 million euros persist in the business.
What will change?
1) The threshold of 2.5 million euros rises to 4 million euros and applies to all companies (including small ones). Foreign investors investing in Belgian shares will therefore also have to raise their threshold to 4 million euros if their stake is smaller than 10%.
2) For large companies, from now on, the participation must be considered as a 'financial fixed asset'. The company must seek a "lasting connection" with the company in which it is investing, and not consider it an investment.
3) The dividends and capital gains that FDI funds pay out are also covered by the FDI deduction, to the extent they originate from normally taxed companies. Upon sale of those funds, a attack of 5% on the added value.
2. Shorter waiting period in liquidation reserve
What is it about?
Through the liquidation reserve can enable owners of a corporation in a tax-efficient way transfer money to their private assets.
What is the current legislation?
After a waiting period of five years you can distribute the liquidation reserve at a favorable rate of 5% withholding tax.
What will change?
The waiting time will be shortened to three years, but the rate rises to 6.5%. Turn over earlier, the normal rate of 30% withholding tax remains in effect.
3. Tax regularization with good faith discount
What is it about?
Who forgotten income or black money wants to declare, can do so through a tax regularization procedure.
What is the current legislation?
The previous arrangement ran from 2016 to 2023, with fines from 20% to 35%, depending on the type of capital.
What will change?
- Would you like a fiscally time-barred capital regularize? Then you pay a fine of 45% on the capital.
- Would you like a non-fiscally time-barred capital regularize? Then the fine amounts to 30%, payable in addition to the tax evaded.
- The statutes of limitations differ according to the type of fraud.
- Heirs or "assigns" (e.g., donors) who are good faith can demonstrate, get 5% discount on these fines.
4. Securities tax: loophole closed
What is it about?
The Court of Audit indicated at the end of 2024 that the declining revenues from the tax on securities accounts might indicate a increasing avoidance.
What is the current legislation?
- The tax on securities accounts is annually 0.15% load in securities accounts where at least 1 million euros on it.
- By spreading across multiple accounts or conversion to registered shares one could stay below the threshold.
What will change?
- Titleholders should henceforth report and motivate. In the absence of any reason other than tax avoidance, the value of the shares converted or securities transferred is counted anyway To determine the taxable threshold.
- Also, the Central Point of Contact (CAP), which contains the balances of all accounts, will be used for control.
5. Expansion of Central Contact Point (CAP).
What is it about?
The CAP is a register of Belgian accounts and financial contracts.
What will change?
- Henceforth, also crypto accounts, gambling accounts over 10,000 euros and financial data of foreign origin recorded.
- The tax authorities will receive a legal framework for anonymous data mining on this data to select suspicious files.
6. Freezing tax limit amounts.
What is it about?
Annual taxable amounts For exemptions and tax credits indexed to keep pace with longevity.
There is now a departure from that.
What will change?
- A number of tax limit amounts will be frozen at the 2025 assessment year ceiling (income and expenses in 2024), and that through the assessment year 2030.
- As of fiscal year 2031 they become re-indexed, without the skipped indexing will catch up.
Specifically, what amounts are involved?
- Dividend exemption (€ 833)
- Interest exemption on savings deposits (€ 1.020)
- Maximum amount of long-term savings (€ 2.450)
- Some tax credits are also affected, such as those for employer shares.
- The freezing of the border for retirement savings is postponed until the fiscal year 2027. For assessment year 2026 (deposits in 2025), the limit remains at:
- €1,050 for a tax benefit of 30%
- €1,350 for a tax benefit of 25%
7. Elimination of interest deduction for second residence.
What is it about?
The federal interest deduction is a tax benefit for those who borrow for property other than their own home, such as a second residence or investment property.
What is the current legislation?
- Owners of a second residence and those who rent to someone who uses the property exclusively for private use will be taxed based on the indexed cadastral income, increased by 40%.
- If the tenant uses premises for their profession or you are renting to a corporation, the rental income actually received charged.
- The interest on a loan be deducted of that taxable income. As a result, a second residence or investment property is not or only partially taxed in personal income tax.
What will change?
Starting in tax year 2026, federal interest deduction disappears completely. Also interest paid in 2025 on existing loans give no tax benefit more.
8. Tax benefits for gifts and other expenses decline
What is it about?
Gifts from at least 40 euros to recognised charities, such as the Red Cross, the King Baudouin Foundation or Fight Against Cancer, entitle you to a tax reduction of 45%.
What will change?
- The gift tax credit decreases to 30% as of fiscal year 2026.
- Lots of other deductions disappear from tax year 2027, such as who incurs expenses for a development fund, a domestic servant or an adoption procedure.
- The tax credit for legal expenses insurance premiums is still granted only for those who paid no later than June 30, 2025 are.
9. Milder approach to first mistake in tax return
What is the current legislation?
For errors in their returns, taxpayers received a automatic elevation of 10%, even if they acted in good faith, provided the undeclared income is higher were then € 2.500.
What will change?
- There will be no more automatic increment on a first error if you bona fide acts. The presumption of good faith is rebuttable by the tax authorities.
- A second error within three years is penalized.
10. Reduced VAT on demolition and reconstruction again for professionals
What is it about?
At demolition and rebuilding of a dwelling on the same plot is subject to a conditional reduced VAT rate of 6% instead of 21%.
What is the current legislation?
- Since the beginning of 2024, construction promoters and developers excluded.
- However, there was a temporary measure provided until June 30, 2025, based on the pre-2024 regime.
What will change?
- As of July 1, 2025 building promoters and developers can permanent of the 6% rate enjoy, although with a limitation in living area (175 m² vs. 200 m² for individuals).
- This restriction does not apply in the case of social rental.
- Among other things landscaping, installation of fences, swimming pools and saunas are excluded from the 6% rate.
- Also for the supply and installation of fossil boilers (such as gas, fuel oil, coal, firewood, briquettes or pellets) applies no reduced rate more.
- The hydraulic pipes, underfloor heating and radiators with their control systems such as thermostatic valves can well still to be installed by 6% btw.
- For repair and maintenance of existing central heating systems remains at the 6 percent rate.
Source: The Time
What does this mean for you as an entrepreneur?
A lot of measures have a direct impact on the tax planning of your business or private assets. Think about investments, real estate, dividends or asset structure. Some rules are already as of this year applicable, others not until 2026.
The program bill will be tabled for a vote in the House at the end of March 2025. We are, of course, closely monitoring these reforms so that we can transform the complex legislation into plain language and clear advice. This allows you to make informed choices.
Do you have questions about these measures?
Feel free to contact us. We are happy to help you!
