Belgium

Residence, personal income tax and additional taxes, inbound taxpayers, non-residents, 2026 capital gains, companies, VAT, regional duties, inheritances, gifts and treaties with France.

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TAX FACTSHEET · 2026-09-26

In this factsheet

Personal and business taxation in Belgium

Documentary position as at 26 September 2026. Unless otherwise stated, the amounts given for personal income tax relate to 2026 income, that is, tax year 2027; the regional rates are those displayed by the sources consulted on that date, with their own dates of application.

1. Identifying the territory, taxpayer and year

1. A Belgian tax rate alone is not enough to determine a tax liability. The Income Tax Code 1992 (*Code des impôts sur les revenus*, CIR 92) distinguishes four taxes: personal income tax on the aggregate income of inhabitants of the Kingdom, corporate income tax on the aggregate income of resident companies, legal entities tax and non-residents tax. The person and their situation must therefore first be characterised by reference to residence, and then the nature of the income. S01 S02

2. Income tax remains a federal tax, but the Regions have their own tax powers. The Special Act of 16 January 1989 allows the Regions to levy additional percentages (*centimes additionnels*) on part of personal income tax, the "reduced State tax" (*impôt État réduit*), and to grant decreases, reductions or increases on those additional percentages. Municipalities and conurbations may also levy an additional tax on personal income tax. S06 S08

3. Registration duties on sales of immovable property, gift duties and inheritance duties fall essentially within the competence of the three Regions: the Brussels-Capital Region, the Flemish Region and the Walloon Region. Their rates differ significantly. The competent Region is determined according to location criteria specific to each tax, in particular, for inheritance, the tax domicile of the deceased at the time of death, assessed over the preceding five years where there have been successive domiciles. S08 S34 S36 S38

4. The reference year must be read with precision. For personal income tax, the income of a calendar year is taxed for the following tax year: 2026 income falls within tax year 2027. Several texts published in 2026 amend rules with retroactive effect from 1 January 2026 or for tax year 2027; the tax on capital gains on financial assets is the main example. S04 S05 S26 S29

2. Individual residence, arrival and departure

5. Inhabitants of the Kingdom are subject to personal income tax. Within the meaning of Article 2, § 1, 1°, of the CIR 92, they are persons who have established their domicile in Belgium or, failing a domicile, the seat of their wealth (*siège de la fortune*) in Belgium. The criterion is factual; it does not rest on a threshold of days of presence laid down in that text. S02 S03

6. Two rules frame this criterion. First, unless proven otherwise, persons registered in the National Register of natural persons are presumed to have established their domicile in Belgium. Second, for married persons who do not fall within the situations of separate taxation provided for in Article 126, § 2, subparagraph 1, the tax domicile is located where the household is established. A declared departure without an actual move of the household must therefore be examined in the light of these two rules, the first being a rebuttable presumption and the second a rule locating the tax domicile. S02

7. An inhabitant of the Kingdom is taxed on their aggregate income, subject to the double taxation conventions. A non-inhabitant is taxed, under non-residents tax, only on income produced or received in Belgium that is taxable under Article 228. A change from one status to the other during the year therefore requires the periods and the income to be distinguished. S01 S12

8. Dual residence under Belgian and French law is resolved by the Franco-Belgian convention of 10 March 1964, still applicable at the date of this factsheet. Its Article 1 applies successively the permanent home, the centre of vital interests, habitual abode, nationality and then agreement between the competent authorities. The convention does not allow residence to be freely chosen. S46 S48

9. Since the Act of 6 April 2026, the transfer of the domicile or of the seat of wealth outside Belgium is treated as a disposal for consideration for the purposes of the tax on capital gains on financial assets. The price is then deemed equal to the value of the asset at the time of the transfer. S09 S26 S29

10. A deferral of payment is granted automatically where the person settles in another Member State of the European Union or of the European Economic Area, or in a State bound to Belgium by a convention providing for exchange of information and assistance in recovery. That deferral ends in particular upon disposal of the assets or their provision as security, and requires an annual certificate. The payment obligation lapses where the taxpayer returns within 24 months or on the expiry of 24 months after the transfer, in accordance with the terms of Article 413/1, § 6. In other States, a deferral may be granted on request, subject to sufficient security. S26 S30

11. Arrival in Belgium is treated symmetrically. For a financial asset held at the time the residence or the seat of wealth is transferred to Belgium, the acquisition value is equal to its value on the first day of liability to personal income tax. Capital gains accrued before arrival are therefore not, in principle, caught by the Belgian tax on capital gains on financial assets. S26 S29

3. Personal income tax and additional taxes

12. Personal income tax applies on an aggregate basis to professional, immovable, movable and miscellaneous income, subject to income taxed separately at its own rates. The progressive scale in Article 130 applies to the taxable income of each taxpayer, including where joint taxation is established for a couple. S04 S10

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Taxable income band, 2026 income	Basic tax rate	Sources
From EUR 0.01 to EUR 16,720	25%	S04
From EUR 16,720 to EUR 29,510	40%	S04
From EUR 29,510 to EUR 51,070	45%	S04
Above EUR 51,070	50%	S04

13. For 2026 income, Article 131 exempts from tax a basic amount of EUR 11,550, increased by EUR 2,030 where the taxpayer has a disability within the legal meaning. These amounts are indexed amounts; they must not be carried over to another income year without verifying the applicable indexation. S05

14. Income taxed separately is outside the progressive scale. Article 171 thus provides, among other things, a rate of 33% for certain miscellaneous income, including speculative profits referred to in Article 90, subparagraph 1, 1°, and internal capital gains referred to in 9°, a), as well as a rate of 16.5% for certain capital gains on immovable property. Aggregation remains applicable where it is more favourable, under the conditions of that article. S09 S10

15. The tax so calculated is not the final burden. Part of the tax, the reduced State tax, bears the regional additional percentages, the total of which, together with the regional reductions and increases, constitutes regional personal income tax. The level of these additional percentages depends on the Region of the taxpayer's domicile; this factsheet does not quantify it. S08

16. The additional municipal tax and the additional conurbation tax are calculated on the total tax. That base is reduced by the portion of tax relating to certain non-professional movable income and, since 1 January 2026, by the portion relating to capital gains on financial assets under Article 90, subparagraph 1, 9°. According to circular 2026/C/74, the separate rates of the tax on capital gains on financial assets therefore apply without municipal additional percentages. The rate is set by each municipality; no single national rate results from Articles 465 and 466. S06 S07 S29

Capital gains on financial assets: the Act of 6 April 2026

17. The Act of 6 April 2026 introducing a tax on capital gains on financial assets was published in the Belgian Official Gazette (*Moniteur belge*) of 21 April 2026, under Numac number 2026002780, according to the Fisconet notes. The text adopted in plenary session of the Chamber on 2 April 2026 is identical to the text adopted at second reading by the Finance Committee (DOC 56 1244/008). The Act takes effect on 1 January 2026. S07 S26 S27

18. Article 90, subparagraph 1, 9°, of the CIR 92 now covers three categories of capital gains realised outside a professional activity, in the course of the normal management of private wealth. These are internal capital gains, realised on securities transferred to a company controlled by the transferor, alone or with their spouse, their descendants, ascendants and collateral relatives up to and including the second degree, or those of their spouse; capital gains on substantial shareholdings of at least 20%; and capital gains on other financial assets. S09 S26

19. Financial assets in the third category include in particular financial instruments within the meaning of the Act of 2 August 2002, certain life insurance contracts and capitalisation transactions, crypto-assets, including non-fungible tokens usable for payment or investment purposes, as well as funds in scriptural or electronic money not held in a payment account, investment gold and central bank digital currencies under the conditions of the text. S26

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Category of capital gain	Treatment provided for	Sources
Ordinary financial assets (Article 90, 9°, c)	10% after an annual exemption of a first band indexed at EUR 10,000 for tax year 2027, with limited carry-forward of the unused portion	S10 S26 S29
Shareholding of at least 20% (Article 90, 9°, b)	Exemption of EUR 1,000,000, reduced by the portion used during the four preceding taxable periods; on the remaining amount, 1.25% up to EUR 2,500,000, 2.5% from EUR 2,500,000 to EUR 5,000,000, 5% from EUR 5,000,000 to EUR 10,000,000 and 10% above	S10 S26 S29
Disposal of a shareholding of at least 20% in a resident company to a legal entity whose principal establishment or seat of management is located outside the EEA (Articles 90, 9°, b, and 171, 4°, l)	16.5% on the capital gain remaining after the exemption of EUR 1,000,000, by way of derogation from the banded rates of 1.25% to 10%	S10 S26
Internal capital gains (Article 90, 9°, a)	33%	S09 S10 S26
Speculative transactions outside normal management (Article 90, 1°)	33%	S09 S10

20. For ordinary financial assets, the statutory basic exemption is EUR 4,855 before indexation; circular 2026/C/74 gives an indexed amount of EUR 10,000 for tax year 2027. The unused fraction may increase the subsequent exemption within the limit of an annual sum and a ceiling set by Article 96/2, with an adjustment provided for income paid or attributed in 2027. These exemptions are reduced pro rata to the months where the taxable period does not cover a full calendar year for a reason other than death, in particular the year of arrival or departure. Capital losses of the same taxable period and of the same category may be offset. S26 S28 S29

21. For assets acquired before 1 January 2026, the capital gain is in principle calculated from the value at 31 December 2025. For listed securities, this is the last closing price of 2025; for unlisted securities, the highest of several statutory values, including a formula based on equity plus four times EBITDA. Instead of that formula, or for assets to which none of the statutory methods applies, the taxpayer may use a valuation at 31 December 2025 drawn up no later than 31 December 2027 by a registered auditor (*réviseur d'entreprises*) or a certified accountant who is not their usual professional adviser. Until 31 December 2030, the taxpayer may request that the historical acquisition value which they demonstrate be used. S26

22. For ordinary financial assets, a 10% withholding tax on movable income (*précompte mobilier*) is withheld by intermediaries established in Belgium from 1 June 2026, but only on financial instruments and on insurance contracts and capitalisation transactions; capital gains on crypto-assets, funds and investment gold must always be declared. The taxpayer may opt out of this withholding and declare the gains themselves; for 2026, that choice had to be notified no later than 31 August 2026. For capital gains on insurance contracts and capitalisation transactions paid or attributed from 1 June to 31 August 2026, the taxpayer is presumed to have opted out of the withholding, unless expressly requested otherwise. Exemptions, a higher acquisition value and capital losses are taken into account, where applicable, by set-off in the tax return. S26 S29

23. The Act is the subject of actions for annulment before the Constitutional Court, concerning in particular the retroactivity to 1 January 2026, the method of collection and the absence of deduction of expenses; a secondary source dated 22 May 2026 mentions case numbers 8661, 8662 and 8663. No decision of the Court on these actions has been identified in the sources consulted. The Act is therefore applied, subject to the outcome of these proceedings. S26 S51

4. The special regime for inbound taxpayers

24. The Programme Act of 27 December 2021 introduced two codified regimes into the CIR 92: the special tax regime for inbound taxpayers (Article 32/1) and that for inbound researchers (Article 32/2). The mechanism does not create a fiction of non-residence: it characterises certain reimbursements by the employer as expenses proper to the employer, which are not taxable. S11

25. An inbound taxpayer is an employee or company director recruited directly abroad by an undertaking registered with the Crossroads Bank for Enterprises, or made available to such an undertaking by a foreign undertaking of a multinational group, to carry on a taxable remunerated activity in Belgium. Excluded, as a director, is a person who performs their duties in their own undertaking, of which they are the founder or co-founder or in which they hold at least 30% of the capital. S11

26. Three cumulative conditions are added. During the 60 months preceding the month of taking up employment, the person must not have been an inhabitant of the Kingdom, nor have resided less than 150 kilometres from the Belgian border, nor have been subject to non-residents tax in respect of Belgian professional income. They must receive gross remuneration taxable in Belgium exceeding EUR 70,000 per calendar year, prorated for the years of arrival, departure or expiry of the regime. Finally, the administration must have given its approval. S11

27. The Act of 18 December 2025 amended the regime for remuneration paid or attributed from 1 January 2025. The remuneration threshold changes from more than EUR 75,000 to more than EUR 70,000. The ceiling on recurring expenses proper to the employer rises from 30% to 35% of gross remuneration, and the absolute ceiling of EUR 90,000 per year is abolished. Retroactive application is provided for certain persons who took up employment between 1 January 2025 and 9 January 2026; the corresponding application had to be filed no later than 9 April 2026, a deadline that had expired at the date of this factsheet. S11

28. In addition to these recurring expenses, the following may be borne tax-free, within the limits of Article 32/1, § 6: removal costs to Belgium, costs of fitting out the dwelling incurred in the first six months, capped at EUR 1,500 subject to indexation, and tuition fees (*minerval*) for private or international schools for children of compulsory school age. The burden of proving the reality and amount of these expenses lies with the taxpayer. S11

29. The regime applies for the duration of the employment in Belgium, up to a maximum of five years, which may be extended by three years if the conditions relating to the employer and the threshold continue to be met. The application is filed electronically by the employer or the company, on pain of forfeiture, within three months of taking up employment; the application for extension must be filed no later than three months after the expiry of the first five-year period. S11

30. For inbound researchers, no remuneration threshold is provided for by Article 32/2, but other conditions specific to the qualification and to the research activity apply. The increase to 35% and the abolition of the EUR 90,000 ceiling also concern them. This factsheet does not detail those specific conditions. S11

5. Non-residents, Belgian-source income and withholding taxes

31. Non-residents tax is levied on income produced or received in Belgium that is taxable under Article 228 of the CIR 92, which lists in particular immovable, movable, professional and miscellaneous income connected with Belgium. A double taxation convention may then limit or eliminate Belgium's right to tax. S12 S46

32. A non-resident who receives in Belgium professional income representing at least 75% of their total Belgian and foreign professional income benefits, under Article 243/1, from the application of a series of deductions and reductions close to those of inhabitants, some of them calculated by taking worldwide income into account. Article 244 provides for a calculation under the personal income tax rules for a resident of another State of the European Economic Area who meets the same 75% condition. S13 S14

33. The withholding tax on movable income (*précompte mobilier*) is set in principle at 30% for income from capital and movable property, subject to the many specific rates in Article 269. It is in particular 15% on the taxable portion of interest on regulated savings deposits exceeding the statutory limits, and 10% for capital gains on financial assets under Article 90, subparagraph 1, 9°, c), since the Act of 6 April 2026. The Programme Act of 30 May 2026 further amended certain rates applicable to dividends from liquidation reserves. S15 S26

34. For a non-resident, the domestic rate is only a starting point. The applicable convention and, where relevant, the transposed European directives may reduce or eliminate the withholding; the reduction requires the recipient to substantiate their residence and, depending on the case, their status as beneficial owner. This factsheet does not reproduce the convention rates, the reading of which requires the consolidated version of the amending protocols. S15 S46

35. The tax on capital gains on financial assets does not apply for non-residents tax, according to administrative circular 2026/C/74. A non-resident is therefore not covered by this new tax; by contrast, the other categories of miscellaneous income taxable under Article 228 and the annual tax on securities accounts, for accounts held with a Belgian intermediary or attached to a Belgian establishment, remain to be examined. S12 S16 S29

6. Companies: residence, corporate tax and the tax on securities accounts

36. A company is resident where it has its principal establishment or its seat of management or administration in Belgium. A company whose registered office is in Belgium is presumed, unless proven otherwise, also to have its principal establishment or seat of management there; proof to the contrary further requires that its tax domicile be established in another State under the legislation of that State. S02

37. The corporate income tax rate is set at 25%. Companies regarded as small companies benefit from a rate of 20% on the first band of EUR 100,000, subject to exclusions. Excluded in particular are companies whose shareholdings exceed certain proportions of their equity, those held at least half by other companies, and those that do not pay at least one director a minimum indexed remuneration, subject to the exception provided for where taxable income does not exceed that remuneration. S20

38. The minimum director remuneration condition was amended by the Act of 15 July 2026, for tax years from 2027. The version consulted mentions an indexed amount of EUR 51,000, required from the fifth taxable period after incorporation, and a new exclusion where the company allocates an excessive share of benefits in kind to its directors. These amendments call for verification of the version applicable to each taxable period. S20

39. Dividends received by a resident company are deducted from its profits as definitively taxed income where, on the date of attribution, it holds at least 10% of the capital of the distributing company or a shareholding with an investment value of at least EUR 2,500,000, the shareholding reaching that EUR 2,500,000 threshold having to take the form of financial fixed assets where the recipient company is not a small company, and where the shares are or have been held in full ownership for an uninterrupted period of at least one year. Article 203 then excludes the deduction for various categories of distributing companies, in particular those not subject to a comparable tax. S21 S22 S23

40. Companies are also concerned by the annual tax on securities accounts, which does not target individuals only. This tax is levied on the average value of the taxable financial instruments held in a securities account during the reference period; it is due only if that average value exceeds EUR 1,000,000. S17 S19

41. For residents, whether individuals, companies or legal entities, the tax covers securities accounts held with an intermediary, wherever it is established; for non-residents, it covers accounts held with a Belgian intermediary as well as accounts forming part of the assets of a Belgian establishment of the non-resident, whatever the intermediary in that case. Since the Programme Act of 30 May 2026, the rate is 0.3% for reference periods ending on or after 1 June 2026, and the tax is limited to 10% of the difference between the taxable base and the threshold. S16 S18

42. The initial rate of 0.15% provided for by the Act of 17 February 2021 therefore no longer corresponds to the rate applicable to reference periods ending after 31 May 2026. The tax also includes exemptions for certain institutional holders and anti-abuse provisions which this factsheet does not detail. S17 S18 S19

7. VAT and indirect taxation

43. The VAT Code entrusts the King, by decree deliberated in the Council of Ministers, with setting the rates and allocating goods and services among them, subject to confirmation by statute within twelve months. The allocation results mainly from Royal Decree No. 20 of 20 July 1970. S24 S25

44. The standard rate is 21%. Royal Decree No. 20 contains a Table A for goods and services at the 6% rate, a Table B for those at the 12% rate and a Table C for those at the 0% rate. Each reduced rate applies only to the headings and conditions of those tables; it cannot be extended by analogy. S25

45. That decree was amended on 14 February 2026 in the context of the multi-year budget agreement. In the coordinated version consulted, Table B includes in particular restaurant services and, since 1 March 2026, the supply of furnished accommodation and camping pitches (heading IV reinstated on that date, the corresponding heading in Table A being repealed), and the heading relating to plant protection products is repealed from 1 March 2026. Any characterisation of a supply must therefore be verified against the version in force at the date of the chargeable event. S25

8. Real estate: acquisition, income and disposal

46. Registration duties on sales of immovable property depend on the Region in which the property is located. The standard rates are not uniform, 12.5% in Brussels and Wallonia and 12% in Flanders, and the preferential regimes for the taxpayer's own home are subject to non-equivalent conditions. S31 S34 S36

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Region	Standard rate on sale	Preferential regime for the main residence	Sources
Brussels-Capital	12.5%	Allowance of EUR 200,000 on the base, if the base does not exceed EUR 600,000, subject to conditions	S34 S35
Wallonia	12.5%	Reduced rate of 3% for the taxpayer's own and only home, since 1 January 2025, subject to conditions	S31 S32 S33
Flanders	12%	Reduced rate of 2% for the only own home, for notarial deeds since 1 January 2025, subject to conditions	S36 S37

47. In Brussels, the allowance requires in particular that the purchaser, a natural person, does not own the whole of another residential property in full ownership at the date of the agreement and undertakes to establish their main residence in the property. For building land, the allowance is limited to EUR 100,000 and to a base not exceeding EUR 300,000. S35

48. In Wallonia, the 3% rate is provided for by Article 44 bis for the acquisition for consideration, by one or more natural persons, of the whole in full ownership of a residential property with a view to establishing their main residence there. The decree of 5 December 2024 abolished, in return, the first-home allowance and the reduced rates for modest dwellings. S32 S33

49. In Flanders, the conditions for the reduced rate were tightened for sale agreements concluded from 1 January 2026. Only acquisitions by natural persons, in full ownership, qualify; a joint purchase with a legal entity causes all parties to lose the reduced rate. The purchaser must undertake to register at the address within three years and to remain registered there for at least one year without interruption. S37

50. For income tax purposes, the disposal of immovable property by an individual is taxable only in the cases referred to in Article 90. These include in particular the disposal of undeveloped immovable property located in Belgium acquired for consideration within eight years of acquisition, and that of developed immovable property located in Belgium acquired for consideration within five years. Article 93 bis, however, excludes in particular the capital gain on a dwelling that has been the taxpayer's own home for at least twelve uninterrupted months before the month of the disposal, under the conditions of the text. Capital gains on land are taxed at 33% in the event of alienation within five years and at 16.5% thereafter, within the statutory period; those on developed property are subject to the 16.5% rate. S09 S10 S53

51. An inhabitant who owns immovable property abroad remains in principle taxable in Belgium on the income from that property, as part of their aggregate income, subject to the convention. The 1964 Franco-Belgian convention allocates income from immovable property, and gains from its alienation, to the State in which the property is situated; Belgium then exempts that income, while being able to take it into account in determining the rate applicable to other income. S01 S46

9. Wealth: no general tax, but targeted levies

52. The sources consulted do not show any general annual tax on the net wealth of individuals. Holding wealth is nevertheless affected by targeted levies: the annual tax on securities accounts above an average value of EUR 1,000,000, the regional immovable property withholding tax (*précompte immobilier*) on Belgian immovable property, not covered in this factsheet, and inheritance and gift duties. S17 S18

53. The 2026 reform shifts attention towards the realisation of capital gains and towards departure. A holder of a large portfolio must now coordinate three elements: the annual tax on securities accounts, the reference value at 31 December 2025 for the capital gains tax, and the rule treating a transfer of domicile as a disposal. S18 S26 S29

54. The Act of 17 February 2021 attached a specific anti-abuse provision to the tax, targeting in particular arrangements designed to remain below the threshold; in addition, the Constitutional Court annulled Article 201/4, subparagraph 6, by its judgment No. 138/2022 of 27 October 2022. This factsheet does not analyse the current scope of these rules; they are sufficient to rule out any mechanical reading of the EUR 1,000,000 threshold. S17 S19

10. Regional inheritances and gifts

55. Inheritance duties payable on the death of an inhabitant of the Kingdom are located where the deceased had their tax domicile at the time of death. If the deceased had their tax domicile in more than one place in Belgium during the five years preceding death, the competent Region is the one in which that domicile was established for the longest period during that time. S08

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Region, direct line and partners (in Wallonia: direct line, spouses and legal cohabitants)	Bands of the net share and rates	Sources
Brussels-Capital, deaths since 1 January 2024	3% up to EUR 50,000; 8% up to 100,000; 9% up to 175,000; 18% up to 250,000; 24% up to 500,000; 30% above	S38
Flanders	3% up to EUR 50,000; 9% up to 250,000; 27% above, calculated separately on the movable and immovable shares of each heir	S40
Wallonia, rates applicable until 31 December 2027	3% up to EUR 12,500, then progressive bands of 4, 5, 7, 10, 14, 18 and 24%; 30% above EUR 500,000	S39
Wallonia, deaths from 1 January 2028	3% up to EUR 12,500, then 4, 5, 7, 9 and 12%; 15% above EUR 500,000	S39

56. In the collateral line and between unrelated persons, the rates are considerably higher. In Brussels, the rate between brothers and sisters ranges from 20% to 65%, and that between all other persons from 40% to 80%. In Flanders, for deaths since 1 September 2018, the rate between brothers and sisters is 25%, 30% and then 55%, and between other persons 25%, 45% and then 55%. S38 S40

57. In Wallonia, the decree of 5 December 2024 reduces the rates for deaths occurring from 1 January 2028. Until that date, the previous rates continue to apply; for persons without a relevant family relationship, the Fisconet note recalls that the top band must be taxed at 80% following judgment No. 107/2005 of the Court of Arbitration. The date of death therefore determines the rate. S39

58. Registered gifts of movable property are subject to proportional duties. The rate is 3% in the direct line and between partners and 7% between other persons in Brussels and Flanders; in Wallonia, it is 3.3% in the direct line, between spouses and between legal cohabitants, and 5.5% for other persons. Gifts of movable property made subject to a condition precedent fulfilled by the donor's death continue to be treated as legacies. S41 S43 S44

59. Gifts of immovable property follow a progressive scale. In the direct line and between partners, Brussels and Flanders apply 3% up to EUR 150,000, 9% up to EUR 250,000, 18% up to EUR 450,000 and 27% above. Wallonia currently applies the same profile in the direct line, but the 2024 decree provides for a new scale, capped at 14% in the direct line and at 20% between other persons, for notarial deeds executed from 1 January 2028. S41 S42 S45

60. The location of gift duties and the choice of the date of a deed therefore matter as much as the rate. The location rules specific to gifts, the family business exemptions, the allowances and the reductions for children are not detailed here; Flanders in particular amended the conditions of the family business regime from 1 January 2026. S08 S52

11. Treaties and international obligations

61. The Franco-Belgian convention of 10 March 1964 on taxes on income, which entered into force on 17 June 1965, remains applicable. A new convention was signed on 9 November 2021. In a parliamentary question of 30 January 2026, the answer to which was published on 6 March 2026, the member of parliament asking the question stated that its entry into force remained conditional on ratification by all the competent parliaments; the minister's answer, which concerned teleworking, does not contradict that finding. No notification of entry into force has been identified in the sources consulted. S46 S47 S48

62. Under its Article 29, the 2021 convention will enter into force upon receipt of the last notification. On the Belgian side, its provisions will apply, for taxes due at source, to income attributed or made payable from 1 January of the following year, and for other taxes on income, to taxable periods beginning on or after that same date; on the French side, Article 29 uses wording that is equivalent in substance, based on the calendar year following entry into force. An analysis of a transaction must therefore not anticipate its application. S47

63. Under the 1964 convention, public pensions and remuneration are in principle taxable in the paying State, with an exception for residents of the other State who are nationals of that State. In March 2026, the minister stated that the competent authorities agreed, for Franco-Belgian dual nationals, to recognise the taxing right of the State of residence, and that the mutual agreement procedure remained open on a case-by-case basis. S46 S49

64. Private pensions and life annuities are taxable in the State of residence of the recipient. Dividends and interest are in principle taxable in the State of residence, the source State retaining a right to withhold tax limited by the convention; other income not covered falls within the State of residence. The 1964 text has been amended by several amending protocols, the consolidated version of which must be read before relying on a convention rate. S46 S47

65. For inheritance, the Franco-Belgian convention of 20 January 1959 allocates the right to tax immovable property to the State in which it is situated, businesses (*fonds de commerce*), ships, boats and aircraft to the State of registration, and other tangible movable property to the State in which it is located at death (Articles 4 to 7); property not covered by those articles is taxable only in the State of the deceased's domicile (Article 8). The State of domicile may also tax the property under Articles 4 to 7 situated in the other State, provided that it credits the tax levied in the latter, and each State may calculate its tax at the average rate taking account of all the property (Article 10). It does not provide for the elimination of double taxation of gifts; its Article 13, § 2, merely makes applicable to registration duties on gifts the rules of § 1 under which public authorities and legal entities of the other State benefit from the exemptions and reductions provided for legal entities of the same nature. S50

66. This factsheet does not list the international reporting obligations, such as the declaration of foreign accounts and insurance contracts, nor the European rules on withholding tax and global minimum taxation. Nor does it deal with the conventions concluded with the United Arab Emirates; each Franco-Belgian-Emirati combination requires a separate reading of the conventions concerned. S01 S46

12. Illustrative cases and limits of application

67. Case 1: a French executive recruited abroad settles in Brussels in 2026 with gross remuneration of EUR 90,000. If, during the preceding 60 months, they have neither resided in Belgium or less than 150 kilometres from the Belgian border, nor been subject to non-residents tax on Belgian professional income, if their employer files the application within three months and if the administration gives its approval, they may benefit from the inbound taxpayer regime; the recurring expenses borne by the employer are then exempt up to 35% of gross remuneration, i.e. at most EUR 31,500 for annual remuneration of EUR 90,000. They remain taxable, as an inhabitant, on their worldwide income. S02 S11

68. Case 2: an inhabitant of Belgium holds a listed portfolio acquired in 2019 and disposes of it in 2026. The capital gain taxable at 10% is in principle calculated from the 2025 closing price, after exemption of the first indexed band: for a capital gain of EUR 50,000 calculated on that basis, with no other capital gain or loss in 2026, the tax would be 10% of EUR 40,000, i.e. EUR 4,000, since the additional exemption can be used for the first time only from tax year 2028; until 2030, they may request that their historical acquisition value be used if they demonstrate it. If their securities account has an average value exceeding EUR 1,000,000, the tax on securities accounts is added. S18 S26 S29

69. Case 3: an entrepreneur holding 40% of a Belgian company transfers their domicile to the United Arab Emirates. The transfer is treated as a disposal for the capital gains tax, and the automatic deferral applies only for a State of the Union, of the European Economic Area or a State bound by a convention covering exchange of information and assistance in recovery. Otherwise, the deferral requires an application and sufficient security. The 40% shareholding falls within the category of shareholdings of at least 20%: the exit tax follows the scale from 1.25% to 10%, applied to the amount remaining after the exemption of EUR 1,000,000. That exemption is reduced pro rata to the months of the taxable period of the year of departure and reduced by the portion already used during the four preceding taxable periods. For example, for a departure on 30 June 2026 with no prior exemption, the period comprises six months: the exemption is EUR 500,000 and an unrealised capital gain of EUR 3,000,000 leaves EUR 2,500,000 taxable at 1.25%, i.e. EUR 31,250 before any deferral. This factsheet does not decide whether the Belgium-UAE convention meets the conditions for automatic deferral. S10 S26 S29 S30

70. Case 4: a person who lived three years in Brussels and then two years in Wallonia dies in the latter Region. Inheritance duties fall within the competence of Brussels, where the tax domicile was established for the longest period during the five years preceding death. If the deceased was domiciled in France, the 1959 convention allows Belgium to tax their Belgian immovable property as well as the property referred to in Articles 5 to 7 registered or located in Belgium, in particular tangible movable property located there at death; France, as the State of domicile, may also tax that property provided that it credits the Belgian tax, and the other property falls within France alone. Under domestic law, however, the transfer duty on death payable in respect of a non-inhabitant covers only immovable property located in Belgium, as provided for example by Article 18 of the Brussels Inheritance Duties Code; the treaty power to tax movable property is therefore not exercised on that basis. S08 S38 S50 S54

71. These reference points do not replace an individual calculation. This factsheet does not quantify the municipal and regional additional taxes, social security contributions, immovable property withholding tax, or all the regional reductions, sectoral regimes, reorganisations, global minimum taxation or reporting obligations. It does not prejudge the outcome of the constitutional challenges to the Act of 6 April 2026. S08 S26 S51

Sources

The texts were consulted on 26 September 2026, mainly in the Fisconetplus database of the FPS Finance, on the website of the Chamber of Representatives and on the portal of the Flemish Region. The Belgian Official Gazette (ejustice.just.fgov.be) and the fin.belgium.be website could not be downloaded automatically; the Official Gazette publication references are taken from the Fisconet version notes. The sources support the statements to which they are attached, without certifying the whole of an individual situation.

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