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After Arizona’s coalition agreement in January and policy statements in March, several new tax measures were introduced.
A first package of tax measures is included in the Program law, which was approved by Parliament on July 18, 2025 and published in the Belgian official Gazette of July 29, 2025 (NL / FR).
In our previous Tax Alert, we provided an overview of the tax measures contained in the Program Law. For further detailed information on each new measure, please refer to that alert.
The alert was prepared in accordance with the draft legislation submitted to and approved by Parliament. However, delays encountered during the legislative process affected the initial implementation timeline. While most provisions were originally planned to take effect on July 1, 2025, these delays led to a revision of the effective date, which now aligns with publication in the Belgian Official Gazette on July 29, 2025, unless otherwise stipulated.
The following provides an overview of the tax measures, along with their corresponding revised dates of entry into force.
|
Tax measure |
Date of entry into force |
|---|---|
|
Dividend received deduction (DRD) – introduction of a new qualitative threshold for medium and large Belgian companies |
From tax year 2026 - Any changes made between February 3, 2025, and the fiscal year-end date that are not justified by reasons other than tax avoidance will not be considered |
|
Extension of this new DRD condition to the withholding tax exemption (“Tate&Lyle”) applicable to dividends paid to certain foreign corporate shareholders |
July 29, 2025 |
|
Harmonization of VVPRbis regime and liquidation reserve |
Dividends paid or allocated as from July 29, 2025 |
|
Exit tax on migrations and beyond |
Eligible transactions as of July 29, 2025 |
|
Annual Tax on Securities Accounts |
July 29, 2025 - The notification obligation is required to be fulfilled for the first time by 31 December 2025, replacing the previously established deadline of 31 October 2025. |
|
Carried interest |
The new rules apply to income paid or allocated as of July 29, 2025. They do not apply to income paid or allocated by a carried interest vehicle that was placed into liquidation on July 29, 2025. The restriction on establishing a liquidation reserve under the updated carried interest regulations will take effect starting in the 2026 tax year. |
|
New permanent 6% VAT rate for demolition and reconstruction |
July 29, 2025 – The 6% rate is also permitted from July 1 to July 29, 2025, under administrative tolerance. |
|
Exclusion of the 6% VAT rate for the installation of environmentally unfriendly heating systems |
July 29, 2025 |
|
Procedural measure - No application of a 10% tax increase in case of a first offense and good faith |
Assessments, enrolled as of July 29, 2025 |
|
Changed “embarkation tax” rates |
July 29, 2025 |
|
New regularization procedure |
July 29, 2025 |