Fiscal Update: Summer Measures 2025

Part 1: The Program Law: What Has Already Been Decided?

The Program Law has now been published in the Belgian Official Gazette on July 29, 2025, and contains numerous tax adjustments that are immediately effective (from July 29, 2025, unless otherwise stated). Here are some key points that entrepreneurs should definitely know:

• Carried interest is recognized as a separate form of movable income and taxed at 25% (instead of 30%). Companies participating in a carried interest vehicle are temporarily not allowed to create a liquidation reserve.
• The exit tax is expanded: in the event of relocation or restructuring abroad, shareholders are deemed to receive a liquidation dividend under certain conditions. There is a new reporting obligation and an option for staggered payment within the EU/EEA.
• The popular liquidation reserve is reformed: the reduced withholding tax rate of 5% upon distribution after 5 years is only retained for liquidation reserves created before January 1, 2026. After that, a 6.5% withholding tax applies with a (shortened) waiting period of 3 years.
• The VVPRbis regime is also tightened. Only those who made a contribution before the end of 2025 still enjoy the favorable 20% rate in the second financial year. Liquidation reserves created for at least 3 years can now also be distributed at a 6.5% withholding tax. The regime of the liquidation reserves is equated with the VVPR-bis regime.
• For the exemption as a DBI deduction, large companies must now record their shareholdings as fixed financial assets.
• New anti-abuse rules for the securities tax make it more difficult to avoid thresholds. Reporting obligations and fines follow.
• Abolition of the tax increase for the first offense in good faith. More clarity is provided on the conditions under which this can happen.
• Additionally, there are measures regarding VAT rates (including demolition and reconstruction of homes at 6% VAT), tax procedures, pensions, social contributions, and a renewed system of fiscal and social regularization.
• In short: this law changes various tax levers in the short term. Waiting is not an option; insight and preparation are crucial.

Part 2: What Is Still on the Table?

On July 3, 2025, the federal government submitted a new bill with various tax provisions. The law has not yet been voted on but contains numerous far-reaching proposals that, if approved, will have consequences from January 1, 2025 (and some only from 2026). What do you need to know today?

• Real estate taxation: the deduction of interest for second homes is abolished, even for existing loans. Other tax benefits for energy-efficient homes or old housing bonuses also disappear.
• Car taxation: for sole proprietorships, a new scheme for hybrid cars would be introduced (temporary extension of the higher deductibility of costs), with degressive deductibility until 2029. For companies, the current restrictions remain. From 2026, fuel costs would be completely non-deductible, regardless of the date.
• Investment deduction: relaxations are coming. The deduction becomes indefinitely transferable, regional certificates for R&D are abolished, and the rates for certain investments are harmonized at 40%.
• Tax credit for the self-employed: the tax benefit for those who invest with their own funds is doubled to 20%, with a maximum of €7,500 from 2025.
• Flexi-jobs: non-retirees receive an increased tax-free threshold of €18,000, now also annually indexed.
• Group contribution & DBI deduction: a new scheme ensures that group contributions can also effectively benefit from the DBI deduction, in accordance with European case law.
• Additional measures: reduction of tax benefits for maintenance payments, stricter rules regarding dependents, freezing of the indexation of certain expenses, abolition of numerous exemptions, and shorter investigation periods for direct taxes and VAT.

Although the bill has not yet been definitively approved, it is likely that these provisions will (partially) become a reality in 2025 and 2026. Looking ahead remains essential.

Part 3: Summer Agreement: What Might Still Come?

On July 21, 2025, the core cabinet reached a political agreement on a series of tax reforms. The texts are not yet available, but the intentions are clear. These proposals may soon be on the table:

Capital gains tax on financial assets:

A brand new tax of 10% on capital gains on shares, bonds, crypto, and insurance products upon sale within the normal management of private assets. For capital gains on large packages (≥ 20% ownership – “significant interest”), there is an exemption up to €1 million, and graduated rates apply from €1 million. In the event of transfer to one’s own holding or family company, a 33% tax may even be due.

A ‘photo moment’ on 12/31/2025 determines the reference value of financial assets. Only future capital gains from 01/01/2026 are taxed. For those who emigrate, an exit tax applies (with deferral possible within the EU/EEA), and there is a step-up upon immigration. Note: the risk of double taxation remains.

Other announced measures (selection):

• Minimum remuneration for the reduced corporate tax rate increases to €50,000, with annual indexation.
• Flat-rate benefits in kind (such as company cars or free housing) above 20% of the total salary package are additionally taxed at 7.5% and can cause the reduced rate to lapse.
• The marriage quotient is phased out.
• The tax-free amount gradually increases to €15,300 by 2029.
• Self-employed persons receive an entrepreneur’s deduction of €650/year (2026) to €900/year (from 2029).
• The tax increase for insufficient prepayment for sole proprietorships disappears.
• New scheme (return) for copyrights in the IT sector.
• ‘Vinted exemption’ up to €2,000 per year for occasional online sellers.

Note: these measures are still conditional. As soon as the legal texts are available, we will inform you again.

Our PKF BOFIDI experts are happy to help you further

Would you like to know more about the new tax measures? Download our brochure with a clear summary of part 1, part 2, and part 3. This gives you additional insights to be well prepared.

Do you have any questions about the fiscal summer measures? Contact our experts, they are happy to help you further.

This article was written by Fikret Seven.