ARTICLE · 20 NOVEMBER 2025

Exit Tax… Or Rather "Stay Tax"?

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A new Belgian "exit tax" regime has been tabled. Here's what you need to know.

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Geoffroy Galéa

A new Belgian "exit tax" regime has been tabled. Here's what you need to know.

Legislative Update

On 27 May 2025, the Belgian government submitted to Parliament a draft programme law that, among other things, introduces a new 'exit tax' regime for shareholders.

While the legislative text partially integrates the concerns raised by the Council of State, the core mechanism remains unchanged: shareholders will be taxed on a deemed liquidation dividend when a Belgian company relocates its statutory seat abroad – regardless of whether the shareholder emigrates or not.

The "Exit tax" in a nutshell

According to this new regime, when/if a Belgian company transfers its statutory seat abroad, its shareholders will be deemed to receive a liquidation dividend – even if they remain in Belgium and receive no actual payment.

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