The new federal coalition agreement (De Wever I): what will change on the tax front?
March 2025 - On 3 February 2025, the federal government De Wever I took the oath of office. The coalition agreement includes a series of fiscal reforms that have yet to be enacted into law. Which measures are in the pipeline in the coming years?
Corporate tax
Small companies will pay a lower corporate contribution, while larger companies will have to pay a higher contribution.
The investment deduction will be transferable indefinitely and increase to 40 per cent for investments in energy, mobility and environment.
The waiting period for distribution of liquidation reserves will be shortened from five to three years. From 2026, the withholding tax on new liquidation reserves rises from 5% to 6.5%.
For hybrid cars, deductibility remains 75% until the end of 2027 and then gradually reduces to 57.5% in 2029. Fuel costs remain 50% deductible until the end of 2027.
International digital tax will be introduced. If there is no international or European consensus by 2027, Belgium will implement its own digital tax.
The contribution to meal vouchers rises from €8 to €12 and the deductibility of employer costs is increased.
SMEs will again be allowed to write off degressively.
The group contribution regime becomes more attractive as indirect shareholdings are also allowed and DBI deduction becomes possible on group contributions.
The FDI deduction is revised: a minimum participation of 10% or an acquisition value of EUR 2.5 million is required. For large companies, this limit is increased to EUR 4 million.
The minimum gross remuneration for the reduced corporate rate rises from EUR 45,000 to EUR 50,000 and is henceforth indexed. Benefits all nature may not exceed 20% of gross salary.
Form 270MLH will be abolished and replaced by an administratively simpler alternative.
Accelerated depreciation is introduced for investments in research, development, defence and energy transition. Large companies will get a temporary regime with a first-year depreciation of 40%.
Capital gains on shares remain exempt from corporate income tax, provided the valuation and participation condition is met.
Personal income tax
The surcharge on the child tax allowance will be reformed so that every child gets the same allowance. Single parents will get this allowance only if they are actually single.
The expat regime will be adjusted: the tax-free allowance will rise to 35%, the ceiling of €90,000 will be abolished and the minimum gross salary will drop to €70,000.
The federal interest deduction for a non-owner-occupied property will be scrapped.
The maximum annual income for flexi jobs rises from 12,000 to 18,000 euros and the hourly wage is increased from 17 to 21 euros. The system will be extended to all sectors.
A tax exemption of up to 2,000 euros is introduced for occasional income, such as second-hand sales.
Tax relief for unemployment benefits will be abolished and that for high pensions will be phased out.
The 180 tax-friendly overtime scheme will be introduced across the board, with burden reduction for employers and tax relief for employees.
Self-employed people will get an entrepreneurial deduction on the first bracket of their profits and gains from 2027, with an increase in 2029.
The tax reduction for donations to recognised institutions falls from 45% to 30%.
The securities tax remains unchanged at 0.15%.
The deductibility of maintenance payments falls from 80% to 50%, and payments outside the EEA are no longer deductible.
The marriage quotient will be halved for non-retirees by 2029.
The increased cost lump sum for distant travel and the special cost lump sum for local mandate holders will be scrapped.
The tax exemption for income from student work will be doubled and the maximum number of working hours will be increased to 650 per year.
A 10% solidarity contribution is introduced on realised capital gains from financial assets, including crypto assets. A €10,000 foot exemption for small investors will apply and historical capital gains will remain exempt.
The copyright tax regime is extended to include the transfer or licence of computer programmes from now on.
Pension savings will be integrated into a classical system with no fiscal impact.
VAT
Administrative simplification: the daily receipt book and various VAT registers are abolished or modified. The nil customer listing will also disappear.
VAT on heat pumps will be reduced from 21% to 6% for a period of five years.
To combat VAT fraud, ‘near real-time reporting’ will be implemented in 2028 for transactions between VAT payers and transactions with a GKS system.
The 6% VAT scheme for demolition and reconstruction will be extended and extended to supplies. The surface area criterion is tightened from 200 m² to 175 m².
The tax administration publishes a circular on the flat-rate right to VAT deduction for company bicycles.
The VAT penalty policy is reformed: mitigating circumstances are taken into account if the treasury has not suffered any financial disadvantage.
There will be a clear definition of ‘renovation’ and ‘renewal construction’, possibly with sustainability criteria.
Administrative simplification
The use of the e-Box will be further extended and made compulsory for public administrations.
Rules regarding Transfer Pricing documentation will be simplified, especially for SMEs.
An ICT platform is being prepared for publications in the Belgian Official Gazette so that they can be filed directly online.
All mandatory information in the UBO register that is already available through other channels will be automatically added to the register.
