Capital gains tax: Why every financial services organization needs a tailored approach

Belgium's new capital gains tax poses challenges for financial institutions, requiring strategic adaptations and clear communication.

In brief

• Starting January 2026, Belgium's capital gains tax will require financial institutions to adapt processes and systems for compliance and client engagement.
• Organizations must upgrade IT systems, enhance product reviews, and create clear communication strategies to manage the new tax regime's complexities.
• A structured project approach is vital, engaging cross-functional teams to ensure readiness, optimize resources, and maintain client trust during the transition.

From January 2026, Belgium will introduce a capital gains tax on financial assets. This reform brings significant complexity and far-reaching implications for financial institutions and Belgian resident investors. The new tax regime requires organizations to rethink their processes, systems, and client engagement strategies to ensure compliance and optimize outcomes.

As of now, the draft legislation for Belgium’s new capital gains tax has not yet been published, even though the entry into force is rapidly approaching. This uncertainty means that organizations will have to deploy tactical solutions and make strategic implementation decisions quickly, all while being mindful not to waste resources on changes that may ultimately need to be revised. Balancing speed with flexibility will be essential to navigate the upcoming new tax.

At EY, we’re following every development closely and understand just how complex and demanding this transition will be. But we also see this as a real opportunity, not just to stay compliant, but to rethink how you serve your clients and strengthen your position in the market.
 

What does this mean in practice?

• Products review 

The tax applies to a wide range of assets: shares, bonds, derivatives, investment funds, ETFs, certain insurance products, currencies and crypto assets. This broad scope means that organizations must conduct a thorough review of their current product offerings to determine which products fall under the new tax regime and consider adaptations to meet client expectations.

• System upgrades for financial institutions

Organizations will need to update internal processes and IT systems to freeze asset values as of 31 December 2025 and track acquisition values for all covered assets acquired from 2026 onwards. This could involve implementing new workflows for categorizing assets, monitoring client transactions, calculating tax liabilities, automating withholding and reporting obligations, and ensuring readiness for new compliance requirements such as capital gains automatic exchange of information when no withholding tax is applied per client choice.

The default nature of the new capital gains tax, meaning that it will apply to (portion of) income not already subject to another tax (e.g. the Belgian Savings Tax), adds a layer of complexity to computations. This complexity is further compounded by the need to integrate these rules with existing tax frameworks, requiring robust data management and adaptable systems to ensure accuracy and compliance.

• Investor communication

Investors will face new choices, such as opting out of withholding tax, and if they want to claim any available tax relief, they will have to do it themselves via their own annual tax return. The complexity of the new tax will force financial intermediaries to develop clear communication strategies as well as consider new support services to help investors understand the implications of the new tax and make informed decisions regarding their portfolios.

Foreign institutions will need to incorporate this new tax and its associated requirements within their tax investor reporting.  

Clear and proactive communication, coupled with robust support systems, will be essential for financial institutions aiming to guide their clients through this period of significant regulatory change. This proactive approach will be critical to maintaining trust and ensuring a smooth transition.

Indeed, EY’s Global Wealth Survey 2025 highlights that as access to a wider variety of products becomes a commodity, financial and non-financial services become the next frontier for wealth managers. Indications point to wealth planning and tax services as key opportunities—reflecting the increasing demand from clients for sophisticated support in navigating regulatory changes and optimizing their financial strategies.
 

Why a project approach is essential

Every organization’s situation is unique. The impacts of the new tax will depend on the nature of the assets, the profile of the clients, and the existing operational setup. A one-size-fits-all solution is not appropriate. Instead, organizations should launch a structured project to:

• identify which products and clients are in scope,
• define clear communication strategies in the short term and adequate client services in the longer term,
• define the best approach based on organizational needs to ensure readiness for day-one compliance while utilizing resources wisely,
• assess and upgrade systems and processes.

To ensure the success of such a project, organizations should establish cross-functional teams involving operations, tax, legal, IT, compliance, and client-facing staff. Setting clear milestones and assigning accountability will help manage the complex interplay between regulatory requirements, technology upgrades, and client communication.

Regularly reviewing progress and adapting the project plan as regulations evolve will further enhance the organization’s ability to respond effectively to both known and emerging challenges.