Belgian Tax Reform – Second Draft Law Moves Forward

The Belgian federal government has reached an agreement on the introduction of a new capital gains tax, which will significantly affect the taxation of financial assets for private individuals and certain legal entities.

Belgium has long been considered a tax haven due to its lack of capital gains tax on financial assets managed within a private estate. The Act of 6 April 2026 introduces a new capital gains tax regime with a 10% fixed rate and generous allowances, including a €1 million exemption for business owners holding at least 20% of company shares. Despite this change, Belgium's competitive tax structure with step-up provisions for new residents and deferred exit taxes may continue to attract entrepreneurs and

Tax residence can be a difficult concept, especially if you have a residence in different countries. This is something Belgian singer Angèle discovered the hard way.

The federal government is asking the wealthiest individuals ("with the broadest shoulders') to make an additional contribution in order to reduce the budget deficit. This will be done in particular through a capital gains...

A Belgian Constitutional Court has referred critical questions to the Court of Justice of the European Union regarding the validity of the Undertaxed Profits Rule (UTPR) under the EU Pillar Two Directive.

Belgian family offices and fund-of-funds utilizing the Privak regime face unique challenges when investing through Luxembourg structures, particularly regarding tax-neutral status requirements and participation exemption conditions. The look-through treatment of transparent entities like SCSps can create complications with underlying assets, prompting the need for alternative structuring solutions that maintain compliance while accommodating diverse investor bases.

Belgium's tax administration has issued a crucial circular clarifying the application of the new capital gains tax on financial assets, addressing key uncertainties around realization timing, earn-out structures, partnership vehicles, and historical exemptions. The guidance provides essential insights for taxpayers navigating payment modalities, matrimonial property regimes, and the complex interaction between the tax and existing corporate structures.

In March 2023, the Belgian Minister of Finance published a proposal for a broad tax reform aiming more generally at modernising and simplifying the tax system and making the system more equitable.

The tax authorities are always looking for their piece of your tax pie. But things get complicated when your income crosses borders. Fortunately, Belgium has double taxation treaties (DTTs) with over 150 countries.

The European Commission has unveiled its most comprehensive EU direct tax framework review to date, shifting policy focus from anti-avoidance measures toward competitiveness and simplification. The Tax Simplification Package promises EUR8 billion in annual savings through sweeping changes to withholding taxes, dividend taxation, interest limitation rules, and cross-border structures. These reforms will fundamentally reshape how businesses structure their European operations, requiring careful analysis of ex