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The draft law concerning various provisions (NL / FR), initially presented to Parliament in early July, was ultimately adopted during the plenary session held on 11 December 2025, although in a revised form. The original draft text and its amendments were extensively debated in Parliament, contributing to the delay of the final vote.
As detailed in our prior alert, the forthcoming legislation includes several tax measures scheduled to take effect on 1 January 2026. In addition to the tax measures included in the Program Law, published in July 2025 (see our alert), this law therefore contains a second set of measures, adopted by Arizona.
Which measures ultimately passed the final vote and in what form will be explained further below.
Note that the voted measures are not included in the budget agreement reached by the government in November 2025. While the budget agreement does cover some tax measures, the related draft legislation has yet to be submitted to parliament. Similarly, draft laws concerning the capital gains taxation and personal income tax reform have also not been officially released. We are keeping a close watch on these developments and will update you as soon as further details are available.
1. Corporate income tax measures
The law concerning various tax provisions includes amendments to the DBI-BEVEK/SICAV RDT, the group contribution regime, and the investment deduction scheme.
During the legislative process, no changes were made to the originally submitted text, nor to the date of entry into force. Accordingly, with regard to these measures, we refer to what was set out in our previous alert.
2. Personal income tax measures
Retroactive changes to Belgian expat regime for incoming tax payers
The new Law of 11 December brings retroactive modifications to Belgium's expatriate tax regime, starting January 1, 2025. For details, see our previous alert. In brief, expats in Belgium will enjoy greater financial benefits and more flexible requirements:
- Increased financial benefit: The cap on recurring additional expenses will be raised from 30% to 35% of gross remuneration, and the previous EUR 90,000 ceiling will be removed.
- Lower salary threshold: The minimum salary requirement will decrease to EUR 70,000, also retroactively applied from January 1, 2025. This change expands eligibility and makes Belgium more attractive to foreign talent.
What does retroactivity mean?
The updated regime introduces significant changes that may impact employees who were previously overlooked. Qualifying employees who started a Belgian employment between January 1st, 2025 and the tenth day after the publication of this law in the Belgian Official Gazette, can still benefit from the regime, provided that an application file is sent to the authorities within 3 months following the publication of this Law in the Official Gazette.
Furthermore for expatriates already under the regime, it may be worthwhile to review if and how the increased financial benefits could be applied.
Mobility
The shift to electric company cars is slower than planned, so the Government decided to extend the transition period for hybrid cars with a new tax deductibility scheme.
Hybrid cars can be deducted up to 100% (resp. 95%) if purchased, leased, or rented until the end of 2026 (resp. 2027), with deductions phasing out by 2029. The new rules will only be applicable to the personal income taxation regime. The deduction formula will no longer include a coefficient based on fuel type for hybrid cars, purchased, leased, or rented after January 1, 2026.
Given the complexity of car taxation regulations, a separate alert will be issued to provide further detailed guidance on these rules.
3. Procedure
The new legislation also shortens certain tax investigation and assessment periods (statute of limitations) with retroactive effect as of tax assessment year 2023 (see for more detail our previous alert). To summarize the new rules:
| Before Tax year 2023 | Current: As of Tax year 2023 | Draft law containing various measures | |
| 3 year | Standard limitation period, regardless of timely, late, or non-filing of tax return | Standard period for timely filed tax return | Standard period for timely filed tax return |
| 34 year | N/A | Late or non-filing of tax return | Late or non-filing of tax return Complex tax return (regardless timely, late, or non-filing) (relates to specific situations a.o. filing local files or CBC reports, reporting payments to non-cooperative jurisdictions, when applying withholding tax exemptions based on a DTT or the EU Parent-Subsidiary Directive or Interest- and Royalty Directive, in case of hybrid mismatches, CFCs, and reporting legal constructions under the so-called Cayman tax rules, etc. |
| 6 year | N/A | Semi-complex tax return, regardless of timely, late, or non-filing of tax return | Pillar two (draft law to amend the law of December 19, 2023, concerning the introduction of a minimum tax for multinational enterprises and large domestic groups) |
| 7 year | Fraud | N/A | Fraud, regardless of timely, late, or non-filing of tax return The wording of the prior notification of the indications of tax evasion as a condition to apply for this period has been amended to more or less the same wording applicable before tax year 2023 requiring a prior written and accurate notification. |
| 10 year | Legal constructions | Complex tax return or fraud, regardless of timely, late, or non-filing of tax return | N/A |
Alongside the shortening of the investigation and assessment periods, the retention period is also retroactively shortened from 10 years to 7 years.
The final version of the law of 11 December provides more detail on applying the four-year investigation and assessment period to ‘complex’ tax returns. It specifies that, for these cases, the fourth year cannot be used to investigate or assess any of the following aspects of the tax return:
- regional taxes, levies and charges;
- fines, forfeitures and penalties of all kinds;
- non-deductible car expenses;
- non-deductible reception expenses and gifts;
- non-deductible restaurant expenses;
- expenses for non-work related apparel;
- social benefits, including benefits for meal vouchers, sport or culture vouchers, or eco vouchers.
4. Other measures
- Real estate taxation: abolition of the interest deduction on loans taken out for acquiring or maintaining immovable property other than the primary residence, also for outstanding contracts, as of assessment year 2026;
- Flexi-jobs - adjusted maximum amount of exempt income as of income year 2025;
- Gradual reduction of the deduction of alimony payments, paid after January 1, 2025, for taxable periods ending after December 30, 2025;
- Various modifications related to exempt income and tax reductions;
- Tax exemption for meal vouchers with a higher employer contribution;
- Abolition of the exemption from capital gains tax on company vehicles, effective after August 31, 2025.
Please consult our dedicated Tax reform website to stay up to date about the legislation process and all EY initiatives that will be organized in this respect. For questions regarding the points discussed, you can also contact your usual EY contact.