Belgium

Flemish fiscal regularisation

The program decree for the Flemish budget 2026 provides a new scheme for the fiscal regularisation of evaded Flemish inheritance and registration taxes.

The Flemish government has opted for a temporary regularisation possibility from 1 January 2026 to 31 December 2029. Only offences committed before 1 July 2025 are eligible for regularisation.

The amounts not barred by the statute of limitations for tax purposes that have not been subjected to inheritance tax and are subject to a regularisation declaration for inheritance tax are subject to a flat-rate regularisation levy of 40% for an acquisition in the direct line or between partners or 75% for an acquisition other than in the direct line or between partners.

The amounts not barred by the statute of limitations for tax purposes that have not been subjected to registration tax and are the subject of a regularisation declaration for registration tax are subject to a flat-rate regularisation levy of 25%.

The amounts barred by the statute of limitations for tax purposes that have been subjected to either inheritance tax or registration tax and are the subject of a regularisation declaration are subject to a flat-rate regularisation levy of 40% if the declaration is submitted in 2026 and 42%, 44%, or 45% if the declaration is submitted in 2027, 2028, or 2029, respectively.

The new scheme provides for a deduction option when declarants, in addition to submitting a regularisation declaration for unpaid regional taxes, have already paid federal regularisation levies.

New capital gain tax on financial assets

Capital gains on financial assets accrued as of 1 January 2026 will become taxable from that date if they fall in the scope of the normal management of a private estate:

• Capital gains realised on financial assets (e.g. financial instruments, some insurance contracts, crypto assets and liquidities) will be taxed at 10% where they exceed 10,000 euros (EUR) (possible carryforward of maximum of EUR 1,000 per annum for maximum five years).
• Capital gains realised upon a sale of shares by an individual who alone or together with one’s close relatives controls the acquiring company would be taxed at 33% (so-called ‘internal capital gains’).
• Capital gains realised upon a sale of shares by an individual who holds 20% of the shares of the company would be exempt up to EUR 1 million and then taxed at graduated rates from 1.25% up to 10% (‘substantial shareholding’). Where it comes to the disposal of a substantial shareholding in a Belgian tax resident company to a non-European Economic Area (EEA) company, the rate is 16.5%.

Although the new capital gain tax legislation is expected to be approved by Parliament in early 2026, it will take effect on 1 January 2026 (except for the withholding tax [WHT]). A transitional provision has also been foreseen.

Proposed personal income tax (PIT) reform

A draft bill has been introduced in Parliament in January 2026, bundling key measures from the government agreement into a package aimed at making work pay more. It also includes provisions to simplify tax rules and eliminate ambiguities, such as the following:

• A gradual increase in the tax-free amount. The supplement to the tax-free amount for the first two dependent children will also be increased, while an indexation freeze will be applied to other supplements. Furthermore, the supplement to the tax-free amount for a single parent will henceforth only be granted to the actual single parent and no longer to parents who are cohabiting in practice.
• From tax year 2030 onwards, the calculation of the tax on the tax-free amount will no longer be based on a separate scale. It will instead be recalculated using the same rate as that of the basic tax, which represents a significant simplification.
• An increase of the minimum remuneration for company directors to EUR 50,000.
• The social integration income (leefloon / revenue d’intégration) will be included in the tax return as replacement income to better account for all sources of income.
• The benefit of the marital quotient for non-pensioners will be halved by 2029, while for pensioners, it will be gradually phased out over a 20-year period.
• A 33% tax will be introduced for pensioners who continue to work after retirement.
• An irrebuttable presumption of normal management for transactions that yield no more than EUR 2,000.
• The introduction of a specific entrepreneurial deduction for self-employed individuals without a company (in a primary or secondary capacity).
• The abolition of the tax surcharge for insufficient advance tax payments for self-employed individuals without a company.
• The tax regime for copyrights will be re-extended to include IT developers.
• A reduction of the special social security contribution to make it ‘single-proof’. For a single person, this would result in a maximum net gain of EUR 350 per year.
• An increase in the work bonus in 2026 to support the lowest wages.
• PhD students who are not subject to income tax will be excluded from the tax credit for dependent children, as is also the case for taxpayers who benefit from treaty-exempt income that is exempt without progression clause.
• Abolition of the tax reduction for unemployment benefits.
• Reduction of the tax reduction for pensions.
• An increase in the number of voluntary overtime hours that can be performed tax-free.
• A lowering of the age limit for young athletes to benefit from a favourable tax regime.