Retrospective changes to the Belgian tax regime for inbound taxpayers

The law of December 18, 2025, makes some significant changes to the current tax regime for inbound taxpayers, applicable with retrospective effect as from January 1, 2025. This development could create opportunities for employers to reduce the cost of employment of their workforce in Belgium. We refer to our previous alert summarizing the changes, which have now been approved.
 

Improved financial advantages, relaxation of qualifying conditions

• Additional recurring costs due to the Belgian employment can now be considered as a tax-free reimbursement of costs proper to the employer up to a maximum of 35% of gross remuneration, instead of the 30% threshold previously applicable.
• The ceiling of EUR 90,000 for the afore-mentioned tax free payment of costs proper to the employer will be abolished.
• The minimum salary requirement to qualify for the tax regime is reduced from 75.000 to EUR 70,000 with retrospective effect from January 1, 2025.
   

Why act now?

• Employees who started their Belgian employment in 2025 and qualify for the updated eligibility criteria can still benefit from the regime, provided that an application is filed with the authorities within a period of 3 months starting from 9 January 2026 (the tenth day after the publication of this Act in the Belgian Official Gazette).
• For qualifying taxpayers already benefiting from the special tax regime, it may be worthwhile to review whether advantage can be taken from the increased benefits.
   

How can EY help?

Our team is ready to assist and:

• screen your workforce for eligibility under the new rules.
• Advise on the retroactive and future implementation of the updated measures to optimize benefits while ensuring compliance and managing risk.
• Provide guidance on administrative formalities and deadlines.