Press & Media

Something went wrong. The page is temporarily unavailable.

Press & Media

Capital gains tax - KBC Brussels Bank & Insurance
Something went wrong. The page is temporarily unavailable.

What does the capital gains tax mean for you?

Capital gains realised on the sale of financial products will be taxed at a rate of 10% with effect from 1 January 2026.

A transitional period applies for the first five months of 2026. From 1 June, KBC Brussels will automatically deduct the 10% capital gains tax, unless you opt out.

Read on to find out what this tax entails and what KBC Brussels will do to help and support you.

For private individuals

The tax applies to:

  • Natural persons who are subject to personal income tax in Belgium
  • Certain legal entities subject to the tax on legal entities (mainly non-profit organisations, foundations and private foundations) An exception is made for entities that are able to receive gifts for which a tax reduction applies.

This means that the tax does not apply to:

  • Companies
  • Natural persons and legal entities that have their tax residence abroad

The capital gains tax has a very broad scope of application. It covers different types of both Belgian and foreign financial products such as shares, bonds, funds, options, trackers, ETFs, warrants, capital redemption insurance, investment-type insurance, gold, foreign currency, crypto assets, etc., both listed and unlisted.

Capital gains tax does not apply to:

  • Group insurance
  • Long-term savings plans
  • Pension savings and other types of non-statutory pension accrual

1. Capital gains

The capital gain is the difference between the amount you receive when selling the product and the amount you paid when purchasing the product. As the new tax takes effect from 1 January 2026, only capital gains accrued on or after that date will be affected. To determine the price of products you have bought before that date, we look at the value of the product on 31 December 2025 (known as the ‘snapshot value’).

Deduction of costs or taxes to reduce the realised capital gain is not permitted.

Example
You bought a share in 2023 at a price of 100 euros, and sell it on 15 September 2026 for 150 euros. Over the entire period, you therefore realise a capital gain of 50 euros. However, the price of the share on 31 December 2025 was 120 euros. As a result, you pay only 10% of 30 euros (150 euros - 120 euros) in tax.

2. Capital losses

It is possible that in addition to capital gains in a given year, you also realise capital losses. You can deduct these capital losses from the capital gains you realised in the same year, across different types of investments. They cannot be carried over from one year to the next.

As capital gains are taxed as from 1 January 2026, capital losses can also be deducted from that date.
You can only set off capital losses in your tax return. If, as intermediary, KBC Brussels withholds the 10% capital gains tax for you, it may not take into account the capital losses you have realised.

Example
In 2027, you realise a total capital gain of 25 000 euros by selling various investments. You also sell some investments in the same year on which you realise a total loss of 3 000 euros. The net taxable capital gain is then 25 000 euros - 3 000 euros = 22 000 euros (leaving aside any exemptions).

3. Historically higher acquisition value

If you bought a share before 31 December 2025 at a higher price than the ‘snapshot value’, you will be allowed to use the higher purchase price instead of the snapshot value.

This option only applies to sales on or before 31 December 2030, and you must state this higher purchase price in your tax return.
However, using a historically higher acquisition value can never result in realising a capital loss. The taxable capital gain will then be reduced to 0 euros.

Example
You bought a share in 2023 for a price of 150 euros. The price on 31 December 2025 (snapshot value) was 120 euros. You sell the share on 15 September 2026 for 125 euros. So you would have to pay 10% on a gain of 5 euros (the difference between the selling price and the snapshot value). However, you didn’t realise a real capital gain as you bought the share for more than you sold it for. Until 31 December 2030, you can apply the historical purchase price that you actually paid.

4. What about purchases at different times?

If the same product was purchased at different times, the calculation of the capital gain is based on the securities purchased first (FIFO principle: first in, first out). This means that, for the calculation of the capital gains tax, the product purchased first is also the first product to be sold.

Example

  • 2026: purchase of 10 shares for a price of 100 euros
  • 2027: purchase of 20 shares for a price of 120 euros
  • 2028: sale of 15 shares for a price of 150 euros

Capital gain on the sale in 2028:

  • Sale of 10 shares purchased in 2026 (150 euros - 100 euros) × 10 = capital gain of 500 euros
  • Sale of 5 shares purchased in 2027 (150 euros - 120 euros) x 5 = capital gain of 150 euros
  • Total taxable capital gain = 650 euros
  • Tax payable: 65 euros (10% of 650 euros)

1. Capital gains

For savings-linked and investment-type insurance products, we look at the difference between the current value of your investment and the total amount you have invested over time.

The new tax applies as from 1 January 2026. For amounts invested before then, the value of your entire investment on 31 December 2025 will be used. This snapshot value constitutes the basis for the calculation.

Capital gains tax is not applicable in the event of a distribution due to the death of the insured.

Example
Your investment is worth 120 000 euros today. The snapshot value on 31 December 2025 was 100 000 euros.

  • Taxable capital gain = 120 000 euros - 100 000 euros = 20 000 euros
  • Tax = 10% of 20 000 euros = 2 000 euros

2. What if you only withdraw a part of your investment?

If you withdraw just part of your investment, a proportionate amount of your total capital gain will only be taxed as well.

Example
Your investment is worth 100 000 euros. Your total capital gain is 20 000 euros.
You withdraw 30% of that amount.

  • Taxable capital gain = 30% of 20 000 euros = 6 000 euros
  • Tax = 10% of 6 000 euros = 600 euros

3. Capital losses

It is possible that in addition to capital gains in a given year, you also realise capital losses. You can deduct these capital losses from the capital gains you realised in the same year, across different types of investments. They cannot be carried over from one year to the next.

As capital gains are taxed as from 1 January 2026, capital losses can also be deducted from that date.
You can only set off capital losses in your tax return. If, as intermediary, KBC Brussels withholds the 10% capital gains tax for you, it may not take into account the capital losses you have realised.

Example
In 2027, you realise a total capital gain of 25 000 euros by selling various investments. You also sell some investments in the same year on which you realise a total loss of 3 000 euros.
The net taxable capital gain is then 25 000 euros - 3 000 euros = 22 000 euros (leaving aside any exemptions).

4. Historically higher acquisition value

If the value of your previous purchase was higher than the snapshot value on 31 December 2025, you may apply the higher purchase price instead of the snapshot value.

This option only applies to sales on or before 31 December 2030, and you must state this higher purchase price in your tax return.

However, using a historically higher acquisition value can never result in realising a capital loss. The taxable capital gain will then be reduced to 0 euros.

Example
The purchases you made prior to 2026 amount to 120 000 euros, the snapshot value is 100 000 euros. In 2027, your investment is worth 110 000 euros.
You may use 120 000 euros as the basis for the calculation, meaning that the taxable capital gain is 0 euros.

5. What about purchases made at different times?

For savings-linked and investment-type insurance products, your investment is taken as a whole for the calculation. There is, therefore, no need to apply the FIFO (first in, first out) principle or to perform a separate calculation each time a purchase had been made.

Example
You invested 20 000 euros in 2026, 30 000 euros in 2027 and 10 000 euros in 2028 (60 000 euros in total). In 2029, your investment is worth 75 000 euros.

  • Capital gain = 75 000 euros - 60 000 euros = 15 000 euros
  • Tax = 10% of 15 000 euros = 1 500 euros

1. How is the capital gains tax applied to securities in foreign currencies?

For financial products in foreign currencies, the law provides that both the purchase price and the sale price must be converted into euros using the exchange rate on the day of purchase and sale to calculate the taxable basis. This ensures that not only the capital gain on the security itself but also the capital gain on the exchange rate is taken into account for the capital gains tax.

Example

  • You buy 100 US shares for a price of 50 dollars each. At the time of purchase, 1 euro is equal to 1.10 US dollars. This means that the price in euros is 4 545 euros (5 000 dollars = 4 545 euros at that time).
  • You later sell the shares for a price of 60 dollars each. At that time, 1 euro is equal to 1 US dollar, which means that you receive 6 000 euros.
  • The exchange rate difference results in a total gain of 1 455 euros (sale price of 6 000 euros minus the purchase price of 4 545 euros). This is more than your gain per share in dollars (1 000 dollars).
  • Consequently, the taxable capital gain is 1 455 euros, with an effective tax of 145.50 euros (10% on 1 455 euros).

2. What happens if you transferred securities from another bank?

We need to know the price you purchased your securities at and the date you purchased them on in order to calculate the capital gains tax correctly. You will find this information in a portfolio statement, a MiFID report or your purchase statement. If you don’t provide us with this information, we will calculate the capital gain on the full sale price.

Some banks have committed themselves to forwarding this information upon a transfer of securities. If your bank is in the list, you don’t have to provide this information yourself. The list will be updated in the future and can be viewed here.

3. What is the Reynders tax?

The Reynders tax is a tax of 30% on the ‘capital gain’ on certain investment funds that invest fully or partially in bonds.
The law provides for a specific method of calculating the new capital gains tax for funds that are subject to the Reynders tax.

So, when selling an investment fund subject to this tax, you are liable to two taxes:

  • 30% withholding tax on the return on the bond portion
  • 10% capital gains tax on the return of the share portion

Example
You buy into a fund in 2026 for a price of 2 000 euros. You sell this fund in 2028 for 2 500 euros. The capital gain is then 500 euros.

Say that the TIS (i.e. the part of the gain derived from the interest component) was 120 euros at the time of purchase and 160 euros at the time of sale, the difference (160 euros - 120 euros = 40 euros) is subject to the Reynders tax of 30%.

So, when selling this fund, you pay the following total amount:

  • Reynders tax: 30% of 40 euros = 12 euros
  • Capital gains tax: 500 euros - 40 euros = 460 euros. 10% of 460 euros = 46 euros
  • Total tax: 58 euros

Every taxpayer is entitled to an annual exemption. No capital gains tax is payable on the first 10 000 euros of capital gains realised. This amount is indexed annually. You need to arrange this exemption in your personal tax return.

In addition, you can carry forward a limited proportion of the exemption you don’t use to the following year. For each year that you don’t make use of this exemption, you can carry forward up to 1 000 euros to a subsequent year, up to a maximum of five years. This makes it possible for each taxpayer to claim a maximum exemption of 15 000. A married couple could therefore end up with a joint basic exemption of 30 000 if they carry forward the full exemption amount (assuming their investments form part of their joint assets).

Example 1

Year

Net capital gain

Exemption carried forward

Basic exemption

Taxable capital gain

2026

0

0

10 000

0

2027

0

1 000

10 000

0

2028

20 000

2 000

10 000

8 000

You don’t realise any capital gains in the first two years. As a result, you can carry forward an exemption amount of 1 000 euros twice, and by 2028 your exemption has increased from 10 000 to 12 000 euros.

In 2028, you realise a capital gain of 20 000 euros. Your exemption is 12 000 euros, which reduces your taxable capital gain to 8 000 euros. Since you have now used the full exemption, no exemption amount can be carried forward to the next year.

Example 2

Year

Net capital gain

Exemption carried forward

Basic exemption

Taxable capital gain

2026

0

0

10 000

0

2027

7 500

1 000

10 000

0

2028

12 500

0

10 000

2 500

You didn’t realise any capital gains in the first year and you can carry forward the exemption of 1 000 euros to the next year.

In 2027, you realise a capital gain of 7 500 euros. You first use the exemption amount of 2026 that was carried forward and then 6 500 euros of your basic exemption. Since you have now used the first tranche of 1 000 euros of your exemption, no exemption amount can be carried forward to the next year.

In 2028, you realise a capital gain of 12 500 euros and your exemption is 10 000 euros (your basic exemption), which means that your taxable capital gain is reduced to 2 500 euros. Since you have now used the full exemption, no exemption amount can be carried forward to the next year.

1. How do you pay capital gains tax after 1 June 2026?

The law provides two ways to pay capital gains tax: 

Option 1: Declare everything yourself (opt-out)

  • You opt for KBC Brussels not to deduct any capital gains tax
  • You can make this choice per custody account or insurance contract
  • You are personally responsible for declaring the realised capital gains on your tax return
  • We report your choice to the tax authorities and provide you with a statement detailing your realised capital gains
  • We provide the tax authorities with an overview of the capital gains you realised after the transitional period
  • Your choice is valid for full-year 2026. If you want to change your choice, it will only take effect from the following year.  

How do you make this choice?

Make a request now in KBC Brussels Mobile
Make a request now in KBC Brussels Touch
  • Or ask Kate in KBC Brussels Mobile for an ‘Opt-out declaration regarding capital gains tax’
  • Alternatively, go to ‘Investments’ in KBC Brussels Mobile > ‘What are you after?’> ‘Capital gains tax opt-out’, or go to ‘Saving & Investments’ in KBC Brussels Touch > ‘What are you searching for? > ‘Capital gains tax opt-out’
  • You can also go to your KBC Brussels branch

Option 2: Automatic deduction (withholding tax)

  • If you don’t opt out, KBC Brussels will automatically deduct 10% capital gains tax when you realise a gain on selling an investment (that will only happen for capital gains you realised on or after 1 June 2026)
  • We will transfer that amount anonymously to the tax authorities
  • If you decide to use the exemption, you can claim back the amount paid on your tax return (we’ll provide you with a statement for this purpose)

How do you make this choice?
You don’t have to do anything for this option.

Tax cannot be deducted at source for certain financial products (such as capital gains on crypto assets, foreign currency and gold). For these products, you are responsible for declaring any capital gains on your personal tax return.

For securities that you hold outside Belgium, you will also have to declare the realised capital gains yourself on your personal tax return.

For non-profit organisations and foundations, the system of deducting the tax at source does not apply; instead, payment of the capital gains tax is arranged directly through the legal entities withholding tax return.

Hold an account jointly with other people?
Every account holder has to make the same choice (declare everything yourself or opt for automatic deduction).

2. How do you pay capital gains tax during the transitional period from 1 January 2026 to 31 May 2026?

The tax applies from 1 January 2026, but a transitional arrangement applies until 31 May 2026.

The legislature provides the option to pay the 10% capital gains tax built up during the transitional period through your bank. From the end of August, we will let you know how you can arrange payment of the capital gains tax. Until then, you don’t have to do anything.

  • If you’ve opted for the tax to be deducted automatically, KBC Brussels will then start deducting the tax from 1 June 2026. You don’t need to do anything.
  • If you choose to opt out, this choice will also apply during the transitional period.

The capital gains tax applies from 1 January 2026; we use the snapshot value of 31 December 2025 to calculate the capital gain.

You can easily find the snapshot value in your documents in the overview of your custody accounts. For your investment-type insurance policies, you will find the value in the annual report of your policies as from March 2026.

How would you like to pay the capital gains tax?

Want tax to be deducted at source? You don’t need to do anything.

Want to opt out? You can submit your choice here:

Make a request now in KBC Brussels Mobile
Make a request now in KBC Brussels Touch
  • Or ask Kate in KBC Brussels Mobilefor an ‘Opt-out declaration regarding capital gains tax’
  • Alternatively, go to ‘Investments’ in KBC Brussels Mobile > ‘What are you after?’> ‘Capital gains tax opt-out’, or go to ‘Saving & Investments’ in KBC Brussels Touch > ‘What are you searching for? > ‘Capital gains tax opt-out’
  • You can also go to your KBC Brussels branch

In 2027, we will provide you with a personalised statement specifying the capital gains and losses you realised in 2026. You can use that document to fill in your tax return.

We are monitoring the situation closely. Information about the subsequent support we will provide will be published on this website. 

For entrepreneurs

Where a private individual realises a capital gain when selling shares, the first question that arises is whether the transactions fall within the definition of ‘normal management of private assets’. ‘Normal management’ is traditionally defined as ‘acts performed by a prudent and reasonable person for the purpose of day-to-day management, but also with a view to the profitability, realisation and reinvestment of elements of their assets’.

Criteria used in the case law to assess whether the realisation of a capital gain is part of the normal management of private assets include the amount of the capital gain, the short period within which the shares were purchased and sold, the intention to make considerable profits in the short term (speculation), the means of financing and any guarantees, the presence of economic motives, the reasons for selling, the financial strength of the buying company, etc.

If transactions do not fall within the framework of ‘normal management’ (and are therefore classed as ‘abnormal management’), realised capital gains are deemed to be ‘miscellaneous income’ and subject to a tax rate of 33% (+ supplementary local tax). In that case, the taxable capital gain is calculated as the positive difference between the price received and the price at which the shareholder (or the shareholder’s legal predecessor) has obtained these shares for valuable consideration (revalorised, where appropriate). The question of whether or not a transaction falls within the definition of ‘normal management’ is obviously a question of fact, on which only a court can provide a definitive ruling.

In the past, the tax authorities generally disputed capital gains realised by a natural person when selling shares to another company (holding company) incorporated or controlled directly or indirectly by this natural person, since this type of ‘internal capital gain’ was not deemed to fall within the definition of ‘normal management’ of private assets. However, the judgement regarding ‘normal management’ can only be made by a court with jurisdiction over the substance of the matter, and the case law is more ambiguous on this point.

The term ‘abnormal management’ and the possible requalification of a capital gain as miscellaneous income continue to exist after the introduction of the current capital gains tax on financial assets, which means that this capital gain may still be taxed as miscellaneous income.
The capital gains tax that is now introduced only applies where transactions are part of the normal management of private assets and are not carried out as part of a professional activity.

Where a shareholder realises a capital gain when selling shares, it should always be checked first whether this is an ‘internal capital gain’. An internal capital gain is realised when shares are sold to a company that is controlled by the seller, alone or together with their family (spouse, legally cohabiting partner, and relatives and collateral relatives to the second degree of the transferor and of their spouse or legally cohabiting partner).

Internal capital gains will be taxed at a separate rate of 33%. A capital gain is defined as the difference between the sale price received and the snapshot value.

We stress that this refers only to internal capital gains that are deemed to fall within the framework of the normal management of private assets. As indicated in the ‘abnormal management’ section, a requalification as miscellaneous income may still be made on the basis of all relevant facts in an individual file. In the latter case, supplementary local tax will also be due on the capital gain and the historical capital gain will be subject to taxation as well (it is highly likely that, under the new regime, the historical capital gain will also be exempt where internal capital gains have been realised).

Please note: in principal, capital gains realised when contributing shares to a holding company will however still be tax-exempt. In fact, a specific regime applies for the contribution of shares, whereby the capital for tax purposes of the company which receives the contribution is limited to the acquisition value of the contributed shares. From a tax perspective, the net contribution is deemed to be a ‘taxed reserve’, which is subject to 30% withholding tax upon subsequent distribution.

Where a shareholder has a substantial interest in a company whose shares they sell (and there are no ‘internal capital gains’, see above), the capital gains tax rules will differ from the standard regime. This deviating rule aims to treat ‘owners’ of (family) businesses (which were often founded by themselves or by relatives from a previous generation) less harshly and is designed not to frustrate the entrepreneurial spirit of these ‘shareholder-entrepreneurs’.

For the purpose of this rule, a ‘substantial interest’ is defined as a participating interest of at least 20%. Only the shareholding held by the shareholder themselves and in their personal name is taken into account. The assessment of whether the holding size condition has been met is made at the time of the transaction. There is no ‘transitional regime’ for shareholders who do not reach the minimum threshold of 20%, but only own, say, 19% of a company’s shares; they will therefore fall under the ‘standard regime’ of 10% tax and a 10 000 euro basic exemption. Shareholders who own at least 20% of the shares will benefit from an exemption on a first tranche of 1 000 000 euros when realising a capital gain. This exemption will apply once per five-year period.

Higher capital gains will be taxed at a progressive rate (1.25% up to 2 500 000 euros; 2.5% up to 5 000 000 euros; 5% up to 10 000 000 euros; 10% for 10 000 000 euros and above). The capital gains tax applies to capital gains on shares of both listed and unlisted companies. For unlisted companies, the question naturally arises as to the ‘initial value’ of the shares (the ‘snapshot value’ on 31 December 2025). A number of options are given for determining this value. If a transaction (between independent parties) took place in 2025 (e.g., a sale of shares), the value used in that transaction can be used as the reference value (‘snapshot value’). In other cases, a flat-rate valuation method (four times EBITDA plus shareholders’ equity) can be used. You may also have a detailed valuation carried out by an auditor (other than your own auditor) or certified accountant (other than your own accountant). This valuation must be made no later than 31 December 2027. Taxpayers may choose the method that yields the highest valuation. However, in exceptional cases, the tax authorities have the option to dispute the value determined by the auditor or accountant.

For the sake of clarity, the scheme is not limited to shares of operating companies. It therefore also applies in principle to capital gains realised on the sale of shares of, for example, a family holding company, a management company or a holding company.

 

Besides capital gains tax, the Coalition Agreement also contains other tax measures for investors.

You should not consider this news item an investment recommendation or advice.

Paying another dividend as soon as possible at 15% withholding tax? - KBC Brussels Bank & Insurance
Something went wrong. The page is temporarily unavailable.

Paying another dividend as soon as possible at 15% withholding tax?

If a company pays dividends to shareholders who are natural persons, in principle 30% withholding tax is applicable. Using the VVPRbis tax reduction scheme and liquidation reserves, this tax burden can be reduced provided certain conditions are met:

The Programme Act of 18 July 2025 largely harmonised the two regimes, bringing the total tax burden in both cases to 15%. However, under the Budget Agreement struck in late November, the tax burden under both systems is set to rise to 18%.

VVPRbis tax reduction scheme: from 15% to 18%

After a (one-off) waiting period, dividends can be paid under this favourable regime with withholding tax being applied at the rate of 15%.

Under the Budget Agreement struck in late November, this rate is set to rise to 18%. According to the latest reports, the rate increase was scheduled to come into effect in the month following publication of the new Act. It is likely that this Act will not be passed until after 1 January 2026, but obviously things can move quickly. All dividends paid after the Act comes into force would immediately be subject to the higher rate, regardless of when the reserves were accumulated.

It may therefore be tempting or even appropriate to pay out another dividend as soon as possible under the VVPRbis scheme, while the 15% withholding tax rate still applies.

However, (accelerated) payment of a dividend raises a number of other questions (apart from the increase in the tax rate): do you need to have funds in your private assets; how many years do you wish to continue working via the company; can the company be sold in the long run (see potential impact on capital gains tax); does the company qualify as a family business (which can be inherited at a tax rate of 3%); will paying the dividend affect the ability to apply a reduced corporation tax rate; and so on. We recommend that the potential tax rate benefit in the event of an accelerated distribution be expressed not just in percentage terms, but also in ‘cash’, and that you weigh this advantage against the other possible consequences of your decision. Of course, your company will also have to follow the appropriate company law procedure (extraordinary or ordinary general meeting of shareholders, net asset test, liquidity test, etc.).

Note that not every company can use the VVPRbis tax reduction scheme. Only companies incorporated after 1 July 2013 (or companies that have since issued new shares in a capital increase or contribution increase) may be (fully or partially) eligible.

Liquidation reserves

When creating a liquidation reserve, a levy of 10% is payable on the amount to be placed in the reserve. In exchange, the reserve can be distributed later at a favourable tax rate.

  • Existing liquidation reserves (and presumably liquidation reserves created before 31 December 2025) can be distributed after a waiting period of five years at a 5% withholding tax rate. Net tax burden: 13.64%
    • It is also possible to opt for a three-year waiting period before distribution of the liquidation reserves. In that case, the withholding tax payable on distribution will be 6.5% rather than 5% as with a five-year waiting period.
    • The increase in the withholding tax rate to 18% would not apply to these previously accumulated liquidation reserves.
  • For reserves created after (presumably) 31 December 2025, the waiting period under the Programme Act would always be three years and the tax rate on distribution 6.5%. Net tax burden: 15%. However, under the recent Budget Agreement, the net tax burden on these reserves would rise further to 18% (by raising the withholding tax rate on distribution after three years to 9.8%).
  • On liquidation, no further tax is currently due on liquidation reserves. This would continue to be the case.

Impact on future capital gains tax?

By distributing reserves before the end of 2025, the company's equity as of 31 December 2025 will decrease and the subsequent taxable basis for private capital gains tax could potentially be higher.

If your company is eventually likely to be liquidated rather than sold, we assume this consideration is less relevant.

You may not construe this newsflash as an investment recommendation or advice.

‘Arizona’ Coalition Agreement: practical details of tax plans for investors - KBC Brussels Bank & Insurance
Something went wrong. The page is temporarily unavailable.

‘Arizona’ Coalition Agreement: practical details of tax plans for investors

Update 26-01-2026

In this post, we take a closer look at the further details of the tax plans and how they will affect investors, both private individuals and entrepreneurs.

For private investors

For entrepreneurs

If a company pays dividends to shareholders who are natural persons, in principle 30% withholding tax is applicable. Using the VVPRbis tax reduction scheme (see below) and liquidation reserves, this tax burden can be reduced under certain conditions.
If a liquidation reserve is created, an additional 10% corporation tax is payable on the amount of the reserve. In exchange, the reserve can be distributed later at a favourable tax rate. The liquidation reserve regime was amended in the Programme Act of 18 July 2025. The Budget Agreement reached within government on 24 November would change this new arrangement with immediate effect. Based on the Budget Agreement published in November 2025, a distinction must be made between liquidation reserves created before 31 December 2025 and reserves created after that date.
  • Under the original regime, existing liquidation reserves (and also liquidation reserves created in the financial year with assessment year 2025 and with closing date no later than 30 December) can be distributed after a waiting period of five years at a withholding tax rate of 5% Net tax burden: 13.64%
    • It is also possible to opt for a three-year waiting period before distribution of the liquidation reserves. In that case, however, 6.5% withholding tax will have to be paid upon distribution. Net tax burden: 15%.
    • The new rate increase agreed in the Budget Agreement (raising the total tax burden to 18%) would not apply to these previously accumulated liquidation reserves.
  • For reserves created on or after 31 December 2025 (assessment year 2026 onwards), the waiting period would always be three years. However, under the recent Budget Agreement, the total tax burden on these reserves would rise further to 18% (by raising the withholding tax rate on distribution after three years to 9.8%).
  • On liquidation, no further tax is currently due on liquidation reserves. This would continue to be the case. We would add the comment that the intention cannot be to liquidate a company in order to then set up another company with (almost) the same object (and certainly not within a period of three years).

Entrepreneurs will have to carefully weigh up what is most advantageous in their specific situation with regard to liquidation reserves that have already been created: accelerated distribution at a withholding tax rate of 6.5% (if there are liquidation reserves that were created three or four years ago) or waiting until the five-year period has expired and then distribution at a withholding tax rate of 5%. Many factors come into play here: how quickly and for what purpose the entrepreneur needs the money for their personal use; what alternative funding options are available from their private assets, etc..

Note that a FIFO (first in, first out) principle applies when distributing liquidation reserves. If you decide to distribute liquidation reserves that are less than five years old, those that are four years old must be distributed first. However, you may be able to distribute those reserves within a few months at (only) 5% withholding tax (once they have been retained within the company for five years).

Tabel Liquidatiereserves
Under the VVPRbis scheme, dividends can be distributed from available profits from the third financial year following the financial year of the company’s incorporation (or capital increase), with withholding tax being applied at a (current) rate of 15%. Note that not every company can use the VVPRbis tax reduction scheme. Only companies incorporated after 1 July 2013 (or companies that have since issued new shares in a capital increase or contribution increase) may be (fully or partially) eligible.

Dividends on shares meeting the conditions of the VVPRbis regime were subject to the following withholding tax rates in the initial arrangement:
  • 30% on distribution of profits for the financial year of incorporation (or capital increase) and for the following financial year;
  • 20% on distribution of profits for the second financial year after the year of incorporation (or capital increase);
  • 15% on distribution of profits for the third financial year after the year of incorporation (or capital increase) and for all subsequent financial years.

The Programme Act of 18 July 2025 abolished the 20% 'middle rate', but only for shares issued after 31 December 2025, leaving only the standard rate of 30% and the concessionary rate (currently 15%) for these shares.

Under the Budget Agreement struck on 24 November, this latter rate is set to rise from 15% to 18%. According to the latest reports, the rate increase was scheduled to come into effect on the first day of the month following publication of the new Act. All dividends paid after the Act comes into force would immediately be subject to the higher rate, regardless of when the reserves were accumulated.

It may therefore be tempting or even appropriate to pay out another dividend as soon as possible under the VVPRbis scheme, while the 15% withholding tax rate still applies.
However, when it comes to the (accelerated) payment of a dividend - apart from the rate increase - there are a number of other questions to consider.

  • Is there a need to hold funds in private assets?
  • How many years does the customer want to continue working through the company?
  • Does the company qualify as a 'family firm' (which can be inherited at a flat rate of 3%)?
  • Will the distribution affect the possibility to apply the reduced corporation tax rate?

We recommend expressing the potential rate benefit of an accelerated payment not only in percentage terms but also in cash terms, and weighing this benefit against any other potential consequences of a decision. Of course, the company will also have to follow the appropriate company law procedure (such as extraordinary or ordinary general meeting of shareholders, net asset test and/or liquidity test, etc.).

When a Belgian company receives dividends from another company, the dividend it receives can be exempted from Belgian corporation tax by applying the 'dividends received deduction' (DRD). For this tax deduction to be applied, three cumulative conditions must be met at the time the dividend is declared.

  1. The taxation condition means that the dividends received must relate to ‘good’ shares, i.e. shares held in companies that are subject to ‘normal’ (and therefore ‘final’) taxation on their profits in the country where they are established. If the company distributing the dividend pays little or no tax on its profits in the country in which it is established (for example a tax haven), the dividend received cannot be exempted.
  2. The holding period condition means that dividends received must relate to shares that are or were held in full ownership for a continuous period of at least one year.
  3. Finally, the company receiving the dividend must hold a participating interest in the distributing company of at least 10% of the capital or with an acquisition value of at least 2 500 000 euros. This is known as the ‘holding size condition’.

The Programme Act changes (tightens up) the holding size condition. if the company receiving the dividends holds less than 10% of the capital of the distributing company, the minimum acquisition value will be maintained at 2 500 000 euros. In other words, the increase to 4 000 000 euros as set out in the Coalition Agreement has not been retained. If the recipient of the dividends is a large company, from assessment year 2026 a participating interest (holding) of less than 10% will moreover have to take the form of a 'financial fixed asset' to be eligible for the dividends received deduction.

For the term 'financial fixed asset', reference is made to the meaning assigned to it in accounting legislation. This implies that the shares held should be included under 'participating interests in affiliated entities', 'participating interests in companies linked by participating interests' or 'participating interests in other financial fixed assets'. Disclosing the participating interest under these line items implies that the company intends to establish a lasting and specific connection with the company in which it invests and therefore does not see the participating interest purely as an investment.

Since the conditions applying for the dividends received deduction and the exemption from capital gains on shares in corporation tax are similar, there is an additional consequence for large companies. Capital gains on shares can only be exempted (for shareholdings of less than 10% and subject to some specific exceptions) if the acquisition value of the shares is at least 2.5 million euros and they are recorded as financial fixed assets.

This stricter holding size condition will apply with immediate effect from assessment year 2026! Changes made between 3 February 2025 and the closing date of the financial year will not be accepted unless it can be demonstrated that the change was motivated by economic (i.e. non-tax-related) considerations.

For small companies, the conditions applying for the dividends received deduction and capital gains exemption on shares will however not change. A company is deemed to be small if at the balance sheet date it does not exceed more than one of the following conditions:

  • Annual average number of employees: 50
  • Annual turnover, excluding value-added tax: 11 250 000 euros
  • Balance sheet total: 6 000 000 euros

(Not) exceeding more than one of these thresholds will only have consequences if it occurs during two consecutive financial years.

Important note: when assessing the conditions, not only the data of the company itself but also of 'affiliated companies' must be taken into account.

A DRD Bevek is an investment company that has to meet a number of conditions. For example, a DRD Bevek must distribute at least 90% of the net income it receives.

A DRD Bevek offers a tax-efficient alternative to equity investments, as it allows the investor to benefit from exemption of dividends and capital gains on shares without having to meet the strict holding size condition and holding period condition (see above). However, the taxation condition must still be met for the DRD Bevek. A DRD Bevek can receive both qualifying and non-qualifying income. Qualifying income is income that meets the taxation condition. The ratio of qualifying income to total income (qualifying + non-qualifying) is calculated on an ongoing basis and produces the 'DRD coefficient'.

Specifically, the company investor can:

  • Receive capital gains exemption on sale of shares of a DRD Bevek in proportion to the DRD coefficient. Under the Miscellaneous Provisions Act, exempt ‘capital gains’ realised on shares of DRD Beveks will in future be subject to 5% tax. In practice, however, the DRD Bevek will essentially always buy back (and immediately cancel) its own shares. In that case, the company-investor does not realise a capital gain on shares, but receives a redemption bonus (= dividend), to which it will be able to (permanently) apply the DRD deduction. The separate 5% assessment does not apply to this redemption bonus.
  • Benefit from the DRD deduction on dividends distributed by the DRD Bevek in proportion to the DRD coefficient.

However, a DRD Bevek is required to deduct the appropriate withholding tax if it pays or declares a dividend. That is in contrast to a repurchase or liquidation bonus, which is not subject to withholding tax. In principle, the deducted withholding tax can be offset against corporation tax and reclaimed by the company-investor.

However, the Miscellaneous Provisions Act means that, from assessment year 2026, offsetting withholding tax against corporation tax will only be possible for dividends received from a DRD Bevek if the receiving company has paid the minimum remuneration for company managers in the income year in which it receives dividends from the DRD Bevek. Under the draft legislation, the minimum managerial remuneration would be raised to 50 000 euros (indexed).

You should not consider this news item an investment recommendation or advice.

KBC Mobile: a Belgian best and world class too - KBC Brussels Bank & Insurance
Something went wrong. The page is temporarily unavailable.

Belgium's best is also world class!

Our fries, waffles and chocolates are not just some of the best products in Belgium, they’re also famous throughout the world. And now we’re proud to add our app to that illustrious list. But don’t take our word for it. Independent research company Sia Partners thinks so too after naming KBC Brussels Mobile ‘Best Banking App in Belgium’.

Like to have Belgium’s best banking app on your phone too?

Get started with KBC Brussels Mobile
Get started with KBC Brussels Mobile
Get started with KBC Brussels Mobile

Why we’re the best in Belgium and beyond

'I’ve just bought a house and KBC Brussels Mobile really proved its worth here. I found solutions to make our home more sustainable and energy efficient. And to top things off, I spotted a Kate Deal that gave me a discount on exactly the DIY materials I needed!"

"When my wallet was stolen, Kate was there to help me block my cards and apply for new ones. Best of all, my new cards were accessible right away in KBC Brussels Mobile which meant I could go shopping the same day as planned!"

"I spent last weekend at the seaside with the girls. We kept track of our shared expenses in KBC Brussels Mobile and later simply split them so everyone could pay their share of the bill. Not only that, we also picked up a tasty Kate Deal for the restaurant we had dinner at!"

‘I was involved in an accident with my car last week. Fortunately, I was able to report the damage really quickly using KBC Brussels Mobile and could even upload photos. Now my car’s in the garage for repairs, I manage my transport needs with KBC Brussels Mobile just as quickly too.’

Get started with KBC Brussels Mobile
Get started with KBC Brussels Mobile
Get started with KBC Brussels Mobile
KBC Brussels Mobile crowned best banking app in the world! - KBC Brussels Bank & Insurance
Something went wrong. The page is temporarily unavailable.