Since Jan. 1, 2025, the Belgian investment deduction system has been completely reworked. The existing principles were retained, but the content of the scheme was adjusted to better reflect investments in digitalization, sustainability and innovation. This introduced different categories, each with its own conditions and percentages. Procedures, such as the attestation requirement, were also more strictly regulated.
At the same time, the recent Easter Agreement announces additional changes for the coming years. This article provides an overview of what applies since 2025 and what changes are still in the pipeline.
1. What has applied since Jan. 1, 2025?
The 2025 reform brought a structure in the investment deduction, with three separate regimes.
1.1. Basic deduction
- Small companies are entitled to a basic deduction of 10%.
- For investments in digital systems (such as security software, certified POS systems or digital CRM packages), an increased rate of 20%.
- This digital deduction is linked to a list of authorized investments (established by the Royal Decree of December 20, 2024).
1.2. Thematic deduction
For investments in themes such as energy efficiency, environmentally friendly technology or carbon-free transport is a increased thematic deductions provided:
- 40% for small businesses
- 30% for other companies
Thematic investments must be explicitly included in a official investment list, and the company must be able to demonstrate that the asset does not cause unreasonable harm to the environment.
1.3. Technology Deduction
For investments in patents and environmentally friendly research and development projects exists a specific technology deduction:
- 13.5% one-time deduction
- or 20.5% if staggered.
This deduction is available to both small and large businesses and requires no more regional attestation, which simplifies the procedure.
1.4. Attestation requirement
An attestation is not required for all forms of investment deduction since 2025, but it is required for specific cases in which the increased thematic deduction is applied.
Specifically, the attestation requirement applies:
- For thematic investments in energy efficiency, environmentally friendly technology or carbon-free mobility, among others;
- Only when the law or executive order provides that explicitly provides (e.g., investments that must appear on an official list);
- The attestation must within three months after the end of the taxable period must be requested from the appropriate federal agency. However, due to the long government formation, this deadline is extended once to 12 months for assets acquired between Jan. 1, 2025 and June 30, 2026.
For investments for which no attestation requirement has been imposed, the general principle remains that the company itself bears the burden of proving that the conditions have been met.
1.5. Cumulative prohibition and transferability
The 2025 scheme includes a cumulverbod:
- Thematic investment deduction may not combined be with regional premiums for the same investment.
- Unless there is a explicit exception provided for in the RD.
What transferability concerns:
- The basic deduction is only transferable for one year.
- The thematic and technology deductions are transferable indefinitely, but there are limits on the annual amount that can be used.
1.6. Alternative: tax credit
- For R&D and technology investments a company can choose to have a tax credit instead of investment deductions.
- This credit will be offset against the corporate income tax payable, is transferable for four years and then repayable.
- Its accounting treatment must correct be done according to the guidelines of the Accounting Standards Commission.
2. What was announced in the Easter Agreement?
The Easter Agreement of the De Wever government provides for additional relaxations and extensions, which, however, are not yet in effect.
The main changes announced are:
2.1. Harmonization of thematic deductions.
- Starting in tax year 2027, the 40% thematic deduction rate would apply to all companies, regardless of their size.
2.2. Unlimited portability
- The current restriction on the portability of the basic deduction would disappear.
- All forms of investment deductions would unlimited can be transferred to future years.
2.3. Lifting the cumulation ban
- The current ban on combining investment deductions with regional subsidies would be abolished.
- This makes it possible to tax advantages and regional aid apply together.
2.4. Additional incentive for digitization among SMEs.
- Small companies would have a additional increase of 10 percentage points get, bringing the total to 30% would bring.
Please note that these reforms were provided for in the Easter Agreement, but have not yet been enacted into law. Thus, as of today, they are not yet applicable. We will keep you informed if there are new developments.
Do you have questions about this?
If so, do not hesitate to contact your customer manager or make an appointment with our pro experts.