Relaxation of Inbound Tax, Social Security, and Immigration Rules in Belgium and the EU

The landscape for global mobility in Belgium and the European Union is evolving rapidly, with several legislative and regulatory changes set to impact employers and internationally mobile employees in the coming months. Below is a summary of the most important developments.

Last week, an amendment was submitted to the draft law containing miscellaneous provisions, currently under parliamentary review. As previously communicated, the minimum gross salary requirement for the Tax Regime for Inbound Taxpayers will decrease from €75,000 to €70,000.

Crucially, the amendment introduces a retroactive effect:

The draft law is adjusted to enable taxpayers to benefit from the retroactive entry into force of the less strict conditions of the regime. Employees who started their employment between 1 January 2025 and the tenth day after publication of the law in the Belgian Official Gazette, and whose gross annual salary is between €75,000 and €70,000, will still be able to apply for the regime. A request can be filed within three months as from the tenth day after publication of the law in the Belgian Official Gazette.

Other notable changes to the expat regime include:

• An increase in the tax-free allowance to 35% (up from 30%)
• Removal of the €90,000 ceiling on the tax-free allowance

From 12 October 2025, the European Union will begin rolling out the Entry/Exit System (EES) across 29 Schengen countries, including Belgium. The EES digitizes border crossings and tracks entry and exit data for non-EU nationals on short stays. This system is particularly relevant for non-EU business travelers entering under visa exemption or on short-term visas.

EES does not impact EU nationals and non-EU nationals holding long term residence rights in the EU.

Key features include automated border checks and biometric data collection, with the aim of identifying overstays and enforcing immigration compliance more strictly. As a first practical consequence, longer waiting times at border crossings are expected during the rollout. It is therefore recommended to allow for extra time for border procedures.

The upcoming EES launch is an ideal opportunity for companies to review their business travel practices and policies. To minimize operational impact, companies should inform their teams and individual travellers upfront allowing a prepared and confident border crossing. A KPMG Flash Alert provides additional details.

We are ready to partner with you to build a future-proof immigration strategy for your organization.

The Belgian Program Law of 18 July 2025 introduces a significant exemption from employer social security contributions on employee earnings above a certain threshold. Effective from 1 July 2025 (third quarter of 2025), this measure aims to bolster Belgium’s competitiveness for high-paying knowledge jobs and curb the shift towards non-contributory remuneration forms and self-employment among highly paid employees. The draft Royal Decree related to these measures was approved by the Council of Ministers on 19 September 2025.

Key features:

• Exemption applies to gross remuneration exceeding €85,000 per quarter for 2025 and 2026, in both the private sector and for contractual employees in the public sector. It is anticipated that the ceiling of €85,000 will decrease to €67,500 per quarter from 2027. However, it is likely that in 2027 the actual amount will be slightly higher than €67,500 as a result of indexation.
• The exemption covers only the basic employer contributions (approx. 25%). Other contributions (approx. 3%) and employee contributions (13.07%) remain payable.
• Certain remuneration elements (e.g., supplementary pension premiums, company cars, mobility budgets, double holiday pay, severance payments, profit-related bonuses) are excluded.
• For employees with multiple jobs, the threshold is apportioned based on the ratio of the basic wage from each employment to the total combined basic salary. The threshold remains €85,000 even for incomplete quarters.
• The exemption can be combined with other employer contribution reductions, but not on the same wage elements or amounts.
• No direct impact on statutory pension rights, as contributions above the threshold do not count towards pension calculations.

The Belgian National Social Security Office has published additional information and payroll codes in its guidelines for the third quarter of 2025. Contributions for this quarter are due by 31 October 2025, making timely compliance essential.

The implementation of this exemption marks a strategic initiative by Belgium to attract and retain highly skilled professionals by reducing employer costs for high earners. Employers should prepare to adjust their payroll systems and evaluate the potential impact on their compensation strategies.