Recent Tax Change And Required Update To Belgian Country Supplements

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.

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.

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...

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.

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.

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

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.

Ireland's Budget 2027 introduces a lower exit tax rate for fund investors, clearer rules for Irish ETFs, and a new Retail Investment Account, while leaving the controversial eight-year deemed disposal rule unchanged. The package also includes Pillar Two updates, interest relief reforms, and a capital gains tax reduction, offering targeted refinements for the financial services sector rather than the fundamental reform many had anticipated.

The Supreme Court, in Delaney v The Personal Injuries Assessment Board, the Judicial Council, Ireland and the Attorney General [2024] IESC10, has upheld the legality...

The Cayman Islands Monetary Authority has introduced sweeping changes to anti-money laundering audit requirements for investment funds, mandating independent audits of entire compliance programmes by September 2026. This marks a fundamental departure from previous practice where internal AML officers could conduct their own testing, raising critical questions about implementation timelines, qualified auditor availability, and compliance costs for funds operating in the jurisdiction.

The EU Retail Investment Strategy is a legislative package which introduces significant changes to the UCITS Directive and AIFMD, as well as MiFID II, the Insurance Distribution Directive and the Solvency II Directive via an omnibus directive (Omnibus Directive).

Ireland has introduced significant amendments to its beneficial ownership registers in 2026, implementing the Sixth Anti-Money Laundering Directive (AMLD6) framework. These reforms fundamentally restructure access rights to the Central Register of Beneficial Ownership of Trusts and Corporate Entities, moving away from unrestricted public access toward a tiered system that balances transparency with privacy rights while maintaining accessibility for legitimate anti-money laundering purposes.

The European Union has reached a political agreement to amend the AI Act, introducing targeted changes aimed at simplifying compliance requirements for businesses while maintaining protective standards.

The Listing Act Directive introduces significant reforms to the MiFID II research regime, allowing investment firms greater flexibility in paying for research and execution services. This briefing examines how the removal of market capitalisation thresholds restores bundling as a commercial option and establishes a new EU framework for issuer-sponsored research.

Following President Trump's recent confirmation that U.S economic sanctions on Iran will be reinstated, Muireann Reedy looks at the penalties ...

The European Commission's proposed overhaul of the SFDR regime is entering crucial trialogue negotiations, with the Irish Presidency aiming to reach agreement by year-end. While the Council and Parliament have aligned on key issues like professional investor opt-outs, significant divergences remain on exclusion criteria for Transition funds, PAI reporting requirements, and engagement strategy disclosures that will shape the future of sustainable finance regulation.

On 1 October 2026, AMLA finalised three sets of regulatory technical standards (RTS) defining key measures companies and professionals must apply to reduce money laundering and terrorist financing risks.