Enhanced tax regime for inbound taxpayers and researchers (Belgium)

Belgium has introduced significant enhancements to its special tax regime for inbound taxpayers, effective retroactively from 1 January 2025. The changes aim to make Belgium more attractive by:

• Lowering the salary threshold for inbound taxpayers from €75,000 to €70,000;
• Allowing retroactive applications for eligible employees until 9 April 2026;
• Increasing the tax-free allowance from 30% to 35% of gross remuneration;
• Removing the €90,000 annual cap on the allowance.

The social security rules remain unchanged until further notice.

The Belgian Parliament has approved significant enhancements to the special tax regime for inbound taxpayers, with the law of 18 December 2025. These changes, aligned with the Federal Coalition Agreement 2025–2029, aim to increase tax benefits and broaden access to the regime, reinforcing Belgium’s attractiveness for international talent.

Background

Belgium’s expatriate tax regime, introduced in the 1960s, was abolished in 2022. In its place, Belgium launched special tax regimes for inbound taxpayers and inbound researchers, designed to reduce the cost of employing foreign talent and strengthen Belgium’s competitive position.

While similar in purpose, the two regimes differ in eligibility:

• Inbound Taxpayer Regime: Requires a minimum annual gross salary but no degree requirement.
• Inbound Researcher Regime: No salary threshold, but requires a PhD or Master’s degree in STEM disciplines or equivalent experience.

Three years after their introduction, further enhancements were implemented in 2025 to make the inbound taxpayer regime even more appealing.

Key changes

The reform focuses on two areas: relaxation of eligibility conditions and expansion of benefits.

1. Relaxed Eligibility Conditions

• Previous rule: Minimum annual gross salary of €75,000, including holiday pay, 13th month, fixed bonuses, and benefits in kind. The remuneration must be taxable in Belgium and borne by the qualifying employer.
• New rule: The salary threshold is reduced to €70,000, effective retroactively from 1 January 2025.

Retroactive Application

Individuals who started employment in Belgium in 2025 but did not meet the previous €75,000 threshold may now qualify retroactively, provided:

• Employment in Belgium commenced between 1 January 2025 and 9 January 2026;
• Annual gross remuneration falls between €70,000 and €75,000 (subject to calculation and prorating rules);
• All other regime conditions are met.

Retroactive applications must be filed by 9 April 2026.

Note: For inbound researchers, the salary threshold remains non-applicable. Other conditions, such as the requirement to have lived at least 150 km from the Belgian border during the previous 60 months and not having earned Belgian taxable income during that period, remain unchanged.

2. Expanded Benefits

• Tax-free allowance: Increased from 30% to 35% of gross remuneration.
• Annual cap abolished: The previous ceiling of €90,000 for the allowance has been removed.

These changes significantly enhance the financial attractiveness of the regime for both employers and employees

Social security

The Belgian social security regime remains unchanged. The Royal Decree of 28 November 1969 has not been amended, meaning these relaxations apply only to income tax. For social security purposes, the rules remain as they were on 1 January 2022.