Program law implementing budget agreement published in Belgian Official Gazette

On 29 May 2026, Parliament has finally approved the program law which includes several tax measures to implement the budget agreement reached on 24 November 2025. The law has been published in the Belgian Official Gazette on 1 June 2026, with some measures entering into force already as from 11 June 2026 and others as from 1 July 2026.

    The program law introduces a new adjustment to the VVPRbis scheme and the liquidation reserve regime following the amendment by the Program Law of 18 July 2025 (see our previous newsletter).

• Regarding the VVPRbis scheme, distributions after the 3-year waiting period will be taxed at 18% instead of 15% from 1 July 2026.
• Regarding the liquidation reserve, distributions from the liquidation reserve after the 3-year waiting period will be taxed at 9.8% instead of 6.5% for liquidation reserves set up for financial years ending on or after 31 December 2025. Together with the initial corporate tax levy of 10% when the liquidation reserve is set up, this also amounts to a total tax of 18%. Any change made to the financial year-end date from 24 November 2025 onwards and which cannot be principally justified by other motives than the avoidance of income taxes will have no effect for the purpose of determining on what date the decreased liquidation reserve was initially set up. The new rules apply to dividends paid or attributed as from 11 June 2026.
  
  Furthermore, the distribution of the liquidation reserve upon liquidation will no longer be exempt if the recipient within 3 years following the distribution directly or indirectly exercises the function of a business leader in a company with the same or similar activities of the distributing company, unless this can be principally justified by other motives than obtaining the exemption. The dividend then becomes taxable in the year in which this fact takes place for the first time within this period of 3 years. In that case, a declaration obligation also applies (no liberating withholding tax). This anti-abuse measure will apply as from 1 July 2026.

While the scope of the regime will again be extended to computer programs, the lump-sum cost deduction of 25% to 50% will only be granted if the taxpayer holds an art work certificate (cfr. article 7 of the Law of 16 December 2022 and article 12, § 8 of the Royal Decree of 13 March 2023). This will apply to income paid or attributed as from 1 January 2026 or, for the purposes of withholding tax, on income paid or attributed as from 11 June 2026.

To limit the budgetary cost of the exemptions from payment of wage withholding tax, a corrective factor must be applied to the exempt amount:

• between 1 January 2027 and 31 December 2027: 97%;
• between 1 January 2028 and 31 December 2028: 93,35%;
• as from 1 January 2029: 95,9%;

This corrective factor applies to all exemptions: night and shift work, research and development, support zones, etc.

Compared to the draft program law, two additional measures have been adopted by amendment:

• the exemption of payment of wage WHT for night and shift labor is aligned with the changes in respect of labor law as from 1 June 2026, and
• the exemption of payment of wage WHT for seasonal labor in the fruit and vegetable sector is reintroduced taking into account the judgment of the Constitutional Court as from 1 January 2026.

Tax on securities accounts

The tax is increased from 0.15% to 0.3% for reference periods ending on or after the date of publication in the Belgian Official Gazette.

Annual tax on credit institutions

Last year, legislation was adopted increasing the bank tax rate from 0.13231% and 0.17581% to 0.15205% and 0.20204% respectively from assessment year 2026, but the draft program law includes a further increase to 0.19286% and 0.25626% respectively from assessment year 2027. In return, the taxable base will be reduced by debts to the European Investment Bank and to central counterparties.

Insurance premium tax

The standard rate of insurance premium tax is increased from 9.25% to 9.6% for premiums due from 1 July 2026.

Tax on the boarding of an aircraft

Following an earlier amendment by the Program Law of 18 July 2025 (see our previous newsletter), the tax will be set uniformly at 10 EUR effective 1 January 2027, regardless of the distance of the flight. For short-distance flights (max. 500 km), the tax will be further increased to 10.5 EUR and 11 EUR from 1 January 2028 and 1 January 2029, respectively.