Taking money out of your company? This is what changes in 2026

The minimum remuneration

To qualify for the reduced corporate income tax rate of 20% on the first EUR 100,000 of profit, an SME company must grant a gross annual remuneration of at least EUR 45,000 to one of its company directors. From 2026, this threshold will be increased to EUR 50,000 per year. This threshold includes any benefits in kind. From next year onwards, such benefits, if calculated on a lump-sum basis, may moreover represent a maximum of only 20% of the total remuneration.

This threshold includes any benefits in kind. From next year onwards, lump-sum calculated benefits may account for a maximum of only 20% of the total remuneration.

Whether it is advisable to actually increase your remuneration is illustrated below using a simplified example. We assume an annual turnover of EUR 120,000 and EUR 15,000 in professional expenses (excluding the annual remuneration).

Based on this simplified example, it is indeed advisable to increase the remuneration to EUR 50,000 on an annual basis.

There are two exceptions to the obligation to grant a minimum remuneration. Even if this condition is not met, the company can still qualify for the reduced rate if:

• your professional activities are no more than four years old;
• your remuneration as a company director is at least equal to the taxable profit of the company.

Dividend distributions

An alternative to the minimum remuneration is a dividend distribution. If you distribute a dividend to yourself, it is in principle subject to 30% withholding tax.

There are two important ways to reduce this general tax rate: the liquidation reserve and the VVPR-bis regime.

Through the Programme Act of 18 July 2025, both systems have largely been harmonised. Initially, the total tax burden in both cases would amount to 15%. However, in the budget agreement of late November, it was decided to increase this tax burden to 18%.

The liquidation reserve

When creating a liquidation reserve, a separate levy of 10% is paid on the amount you wish to reserve. This reserve can then be distributed at a later time at a more favourable rate.

Until recently, you had to wait five years to distribute the liquidation reserve with only 5% additional withholding tax. The effective tax burden on the original profit therefore amounted to 13.64%, since this 5% is calculated on the net amount after the earlier 10% levy.

For reserves created as from 2026, the waiting period is shortened to three years, but the additional withholding tax increases to 6.5%. The total tax burden therefore amounts to 15%. According to the recent budget agreement, this could even increase further to 18%. The intention is, however, not to affect liquidation reserves already built up.

Upon liquidation of the company, no additional tax is due on liquidation reserves.

For liquidation reserves that have already been created – as well as those that will still be created before 31 December 2025 – a transitional regime applies. You can choose:

• to wait five years and pay 5% additional withholding tax;
• or to distribute after three years at 6.5% (provisional rate).

An important point of attention is the FIFO principle (first in, first out). Those who decide to distribute earlier will automatically first draw on the oldest reserves. It may therefore happen that you pay 6.5% on reserves that would have been available at 5% a few months later.

A distribution within the waiting period remains possible, but at a higher tax cost. In that case, the withholding tax amounts to 20%. For reserves created as from 2026 and distributed within the waiting period, this even increases to 30%.

Anyone intending to wind up the company in the foreseeable future is usually better advised not to distribute liquidation reserves anymore. Upon liquidation, they can be distributed without additional taxation.

VVPR-bis

In addition to the liquidation reserve, there is the VVPR-bis system, which currently also results in a net tax burden of 15%. The main difference lies in timing and cash flow.

Under VVPR-bis, withholding tax is only paid upon distribution. After the (one-off) waiting period – following the issuance of the shares, at incorporation or upon later capital increases – money can be distributed at 15%.

Please note: not every company qualifies. Only SME companies incorporated after 1 July 2013, or that have carried out a capital increase since then, can (partially) make use of VVPR-bis.

Investing during the waiting period

Funds held during the waiting period of liquidation reserves or VVPR-bis can be invested in a tax-efficient manner, often through DBI funds (Dividends Received Deduction funds).

• Capital gains: realised capital gains within the fund are not taxable. From 1 January 2026, however, a capital gains tax of 5% would apply, unless the fund itself repurchases its shares – which is usually the case in practice.
• Withholding tax: withholding tax deducted on dividends from the DBI fund can be recovered by the company through corporate income tax. To apply this recovery, the minimum remuneration of EUR 50,000 as a company director must be met. Only those who meet this condition can still recover withholding tax on DBI dividends.

Please note: the reform does not stop with liquidation reserves and DBI. From January 2026, a capital gains tax on shares will also be introduced. Although these plans are not yet definitive, it may be useful to distribute reserves in 2025. This reduces equity and affects the future taxable base for the capital gains tax. As historical capital gains up to 31/12/2025 are exempt, it may in some cases be tax-efficient to distribute a dividend.

Our PKF BOFIDI experts are here for you

Would you like to know what these changes specifically mean for your company? Contact us and we will together assess which strategy is most advantageous for your situation.

This article was written by Stijn Schalck.