Belgian cross-border tax for 2026: who is a Belgian tax resident (home or seat of wealth, the National Register presumption, and the company test of main establishment or seat of management); arriving under the special tax regime for inbound taxpayers and researchers (35% cost allowance, EUR 70,0…
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Accountant-authored. Written and published by Ryan Duguid, an accountant approved on OpenAccountants. Their licence number is not on file. Their registration is in Australia; this skill covers Belgium. General reference material, not advice on your specific facts; don't file, pay, or take a position on it without a professional reviewing your situation.
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| Item | 2026 figure | Tax year | Source |
|---|---|---|---|
| Inbound regime (BBIB): minimum gross pay | More than EUR 70,000 a calendar year, pro rata in the year of arrival or departure (was more than EUR 75,000 to 31 December 2024) | Pay from 1 January 2025 | Art. 32/1, §3 WIB 92; Circular 2026/C/51 |
| Inbound regime (BBIB and BBIO): tax-free recurring cost allowance | Up to 35% of gross pay, no annual cap (was 30% capped at EUR 90,000) | Pay from 1 January 2025 | Circular 2026/C/51 |
| Inbound regime: home furnishing costs | Up to EUR 1,500 (one-off, first six months) | 2026 | Art. 32/1, §6 WIB 92 |
| Inbound regime: duration | 5 years, extendable by 3 years | 2026 | Art. 32/1, §7 WIB 92 |
| Inbound regime: look-back | Not resident, not living within 150 km of the Belgian border, and not subject to BNI on professional income in the 60 months before starting work | 2026 | Art. 32/1, §3 WIB 92 |
| Personal income tax scale (residents, and non-residents via art. 243 and 243/1) | 25% to EUR 16,720; 40% to EUR 29,510; 45% to EUR 51,070; 50% above | Income 2026 | Art. 130 WIB 92 (income 2026) |
| Tax-free amount (residents, and qualifying non-residents under art. 243/1) | EUR 11,550 basic amount (plus EUR 2,030 if disabled), as amended by the law of 15 July 2026 (Belgian Official Gazette 29 July 2026) from assessment year 2027 | Income 2026 | Art. 131 WIB 92 (income 2026) |
| Non-resident surcharge instead of municipal tax | 7 additional centimes (7% of the federal tax). The statute says 6, raised to 7 by royal decree | Income 2026 | Art. 245 WIB 92; art. 80 KB/WIB 92 |
| 75% rule for non-residents | Belgian taxable professional income at least 75% of total worldwide professional income gives resident-style allowances and deductions | Income 2026 | Art. 243/1 WIB 92 (income 2026) |
| Exit tax on financial assets (individuals leaving) | 10% of the latent gain since 31 December 2025; 1.25% to 10% if a substantial interest (at least 20% of the rights in the company, held directly) | Departures from 1 January 2026 | Circular 2026/C/74, nos. 153 to 156 |
| Capital gains basic exemption | EUR 10,000 a year (indexed amount for assessment year 2027), reduced pro rata by months when the taxable period is not a full calendar year, as in the year of departure; EUR 1 million for a substantial interest, available over 5 consecutive taxable periods and also reduced pro rata | Income 2026 | Art. 129/1 WIB 92; Circular 2026/C/74, nos. 51, 92, 99 and 155 |
| Company moving its seat or main establishment abroad | Treated as a liquidation (art. 208 and 209 apply); corporate tax at 25% (20% on the first EUR 100,000 for small companies) | Income 2026 | Art. 210, §1, 4° WIB 92; art. 215 WIB 92 |
| Company exit charge, EU/EEA move: spread payment | One fifth within two months of the assessment notice, the rest in four equal yearly instalments | Income 2026 | Art. 413/1, §2 WIB 92 |
| Withholding tax (roerende voorheffing) on dividends, interest, royalties | 30% general rate | Income 2026 | Art. 269, §1, 1° WIB 92 (income 2026) |
| Withholding: copyright income | 15% on the first band (EUR 77,220 indexed) | Income 2026 | Art. 269, §1, 4° WIB 92 |
| Withholding: dividends of small companies on new shares (VVPR-bis) | 20% for the second financial year after a contribution made by 31 December 2025; 18% for the third and later financial years (the 18% rate applies to dividends allocated or paid from 1 July 2026, programme law of 30 May 2026) | Income 2026 | Art. 269, §2 WIB 92 |
| Withholding: capital gains on financial assets (art. 90, 9°, c)) | 10%, withheld only when the recipient is a Belgian resident; never on the exit tax gain. The capital gains tax does not apply in the non-resident tax (Circular 2026/C/94) | From 1 June 2026 (law of 6 April 2026, art. 35, second paragraph); the tax itself applies to gains from 1 January 2026 | Art. 269, §1, 5° WIB 92 |
General reference only. This skill is general tax reference material for AI-assisted work. It has not been reviewed for any person's facts. Do not rely on it to file, pay or take a tax position without review by a qualified professional in Belgium.
This is the cross-border hub for the Belgian pack. It covers what changes when a person or a company crosses the Belgian border, and it points to the other Belgian skills for the detail:
be-income-taxbe-social-contributionsbelgium-payrollbelgium-crypto-taxbe-corporate-tax (open as PR #553, not yet merged on 22 October 2026)Tax year. Belgium taxes the calendar income year. Income year 2026 is assessment year (aanslagjaar) 2027. Figures below are for income year 2026 unless the row says otherwise.
2026 is a year of change. Three 2025-2026 laws matter here: the law of 18 December 2025 (inbound regime), the law of 6 April 2026 (a new tax on capital gains on financial assets, with an exit tax, from 1 January 2026) and the law of 15 July 2026 (personal income tax changes, including a part of art. 244bis for non-residents from assessment year 2027). For the capital gains tax itself (scope, exemption, step-up, rates), see be-capital-gains.
A person is a Belgian resident (rijksinwoner) if they have their home (woonplaats) in Belgium or, if they have no home in Belgium, their seat of wealth (zetel van fortuin) there (art. 2, §1, 1°, a) WIB 92). Both are judged on the facts: where the family lives, where the person's life is organised, where assets are managed.
A resident is taxed on worldwide income. A non-resident is taxed only on income listed as Belgian-source (art. 227 and 228 WIB 92).
A company is a domestic company (binnenlandse vennootschap) if it has its main establishment (voornaamste inrichting) or its seat of management (zetel van bestuur of beheer) in Belgium (art. 2, §1, 5°, b) WIB 92). A company with its registered office in Belgium is presumed to have its main establishment or seat of management there. The counter-proof is accepted only if the company also shows that it is tax resident in another state under that state's law.
A foreign company with a Belgian establishment (Belgische inrichting) is taxed in Belgium under the non-resident tax for companies on the income of that establishment (art. 227, 2° and 229 WIB 92).
Diplomats and other Belgian state officials posted abroad are residents by special rule (art. 2, §1, 1°, b) to d)); refer them. International organisation staff (EU, NATO and others) have their own rules; refer them.
| Item | 2026 figure | Tax year | Source |
|---|---|---|---|
| Inbound regime (BBIB): minimum gross pay | More than EUR 70,000 a calendar year, pro rata in the year of arrival or departure (was more than EUR 75,000 to 31 December 2024) | Pay from 1 January 2025 | Art. 32/1, §3 WIB 92; Circular 2026/C/51 |
| Inbound regime (BBIB and BBIO): tax-free recurring cost allowance | Up to 35% of gross pay, no annual cap (was 30% capped at EUR 90,000) | Pay from 1 January 2025 | Circular 2026/C/51 |
| Inbound regime: home furnishing costs | Up to EUR 1,500 (one-off, first six months) | 2026 | Art. 32/1, §6 WIB 92 |
| Inbound regime: duration | 5 years, extendable by 3 years | 2026 | Art. 32/1, §7 WIB 92 |
| Inbound regime: look-back | Not resident, not living within 150 km of the Belgian border, and not subject to BNI on professional income in the 60 months before starting work | 2026 | Art. 32/1, §3 WIB 92 |
| Personal income tax scale (residents, and non-residents via art. 243 and 243/1) | 25% to EUR 16,720; 40% to EUR 29,510; 45% to EUR 51,070; 50% above | Income 2026 | Art. 130 WIB 92 (income 2026) |
| Tax-free amount (residents, and qualifying non-residents under art. 243/1) | EUR 11,550 basic amount (plus EUR 2,030 if disabled), as amended by the law of 15 July 2026 (Belgian Official Gazette 29 July 2026) from assessment year 2027 | Income 2026 | Art. 131 WIB 92 (income 2026) |
| Non-resident surcharge instead of municipal tax | 7 additional centimes (7% of the federal tax). The statute says 6, raised to 7 by royal decree | Income 2026 | Art. 245 WIB 92; art. 80 KB/WIB 92 |
| 75% rule for non-residents | Belgian taxable professional income at least 75% of total worldwide professional income gives resident-style allowances and deductions | Income 2026 | Art. 243/1 WIB 92 (income 2026) |
| Exit tax on financial assets (individuals leaving) | 10% of the latent gain since 31 December 2025; 1.25% to 10% if a substantial interest (at least 20% of the rights in the company, held directly) | Departures from 1 January 2026 | Circular 2026/C/74, nos. 153 to 156 |
| Capital gains basic exemption | EUR 10,000 a year (indexed amount for assessment year 2027), reduced pro rata by months when the taxable period is not a full calendar year, as in the year of departure; EUR 1 million for a substantial interest, available over 5 consecutive taxable periods and also reduced pro rata | Income 2026 | Art. 129/1 WIB 92; Circular 2026/C/74, nos. 51, 92, 99 and 155 |
| Company moving its seat or main establishment abroad | Treated as a liquidation (art. 208 and 209 apply); corporate tax at 25% (20% on the first EUR 100,000 for small companies) | Income 2026 | Art. 210, §1, 4° WIB 92; art. 215 WIB 92 |
| Company exit charge, EU/EEA move: spread payment | One fifth within two months of the assessment notice, the rest in four equal yearly instalments | Income 2026 | Art. 413/1, §2 WIB 92 |
| Withholding tax (roerende voorheffing) on dividends, interest, royalties | 30% general rate | Income 2026 | Art. 269, §1, 1° WIB 92 (income 2026) |
| Withholding: copyright income | 15% on the first band (EUR 77,220 indexed) | Income 2026 | Art. 269, §1, 4° WIB 92 |
| Withholding: dividends of small companies on new shares (VVPR-bis) | 20% for the second financial year after a contribution made by 31 December 2025; 18% for the third and later financial years (the 18% rate applies to dividends allocated or paid from 1 July 2026, programme law of 30 May 2026) | Income 2026 | Art. 269, §2 WIB 92 |
| Withholding: capital gains on financial assets (art. 90, 9°, c)) | 10%, withheld only when the recipient is a Belgian resident; never on the exit tax gain. The capital gains tax does not apply in the non-resident tax (Circular 2026/C/94) | From 1 June 2026 (law of 6 April 2026, art. 35, second paragraph); the tax itself applies to gains from 1 January 2026 | Art. 269, §1, 5° WIB 92 |
Residents: worldwide income. Belgium has no remittance basis and no non-domiciled status. A resident reports worldwide income. Foreign professional income that a treaty exempts gets the reduction for foreign income (art. 155 WIB 92): it is left out of the tax but counts for the rate.
Non-residents: Belgian-source income only (art. 228 WIB 92). The common cases are Belgian real estate income, pay for work done in Belgium, director's fees from a Belgian company, profits of a Belgian establishment, and Belgian dividends and interest (usually settled by withholding). The tax is computed on the art. 130 scale plus 7 additional centimes (art. 245 and art. 80 KB/WIB 92). Two cases:
Inbound regime (BBIB for employees and directors, BBIO for researchers; art. 32/1 and 32/2 WIB 92). The person stays a Belgian resident taxed on worldwide income. The benefit is that the employer can pay, on top of salary, recurring costs of the move and the Belgian posting as a tax-free reimbursement of the employer's own costs, up to 35% of gross pay, with no cap from 1 January 2025. One-off costs are also tax-free: the move itself, home furnishing up to EUR 1,500, and school fees at a private or international school for children of school age. Conditions:
Exit tax on financial assets (from 1 January 2026). When a resident who owns financial assets stops being a Belgian resident by moving their home and seat of wealth abroad, the latent gain on those assets is taxed as if they had been sold (art. 92, §2, 2° WIB 92). The "price" is the value of each asset on the day the person leaves. Gains that arose before 1 January 2026 are exempt: for assets bought before that date, the gain is measured from the value on 31 December 2025 (the "snapshot"). The rate is 10%, or the substantial-interest rate of 1.25% to 10% if the person held a substantial interest of at least 20% (art. 90, 9°, b)). The basic exemption of EUR 10,000 (or the EUR 1 million substantial-interest exemption) applies, reduced pro rata by months because the resident taxable period ends on departure (art. 129/1 WIB 92; Circular 2026/C/74, nos. 99 and 155). Each calendar month whose 15th day falls in the resident period counts as a full month. No withholding tax is due on the exit gain, so it must be reported on the resident return for the year of departure (Circular 2026/C/74, no. 120). A usufructuary who leaves does not trigger a gain for the bare owner. A person who becomes resident takes the assets at their value on the first day of residence (art. 102, §3 WIB 92), so pre-arrival gains are not taxed. Exception: a person who returns within 24 months of leaving, so that the deferred exit tax lapses, keeps the original acquisition value (Circular 2026/C/74, nos. 150 and 151).
Company exit. Moving a Belgian company's main establishment or seat of management abroad is treated as a liquidation (art. 210, §1, 4° WIB 92). Latent gains and untaxed reserves become taxable, and the part of the net assets treated as a distributed dividend falls under art. 208 and 209. For operations from 29 July 2025, that deemed dividend is also a taxable dividend for the shareholders, to the extent it relates to assets no longer used or kept in Belgium (art. 18, first paragraph, 2°quater WIB 92, programme law of 18 July 2025). If the company does not support it with individual forms (fiches), the separate assessment of art. 219 applies. For operations from 29 July 2025 to 31 December 2025, the administration does not require the forms and does not apply art. 219, but the dividend stays taxable for the shareholder (Circular 2026/C/70). A Belgian establishment of a foreign company that moves assets out is taxed on the gain (art. 228, §2, 3°bis). The 25% corporate rate applies (art. 215). For a move to an EU or EEA state with a recovery assistance agreement, the tax on those gains can be paid in five yearly parts (art. 413/1). See be-corporate-tax once merged for the computation.
| Event | What to do | When | Source |
|---|---|---|---|
| Arriving | Register at the commune (gemeente/commune) of residence; this puts you in the National Register | On arrival | Art. 2, §1, 1° WIB 92 (presumption) |
| Inbound regime application | Employer applies electronically, with an attestation signed by the employee | Within three months of starting work in Belgium; time limit is strict (op straffe van verval) | Art. 32/1, §8 WIB 92 |
| Administration decision | Written decision to employer and employee | Within three months of receiving the application | Art. 32/1, §8 WIB 92 |
| Inbound regime extension (3 years) | Employer applies electronically | No later than three months after the first five-year period ends | Art. 32/1, §8 WIB 92 |
| Change of employer under the regime | New employer files a new application | Within three months of the new start | Art. 32/1, §9 WIB 92 |
| Employer reporting | Gross pay and the two kinds of cost reimbursements on the 281.10 form | With the annual tax forms | Art. 32/1, §10 WIB 92 |
| Leaving | Deregister at the commune; file the resident return for the resident part of the year and, if there is Belgian income after departure, a BNI return | In the normal filing season for the income year | Art. 227 to 248 WIB 92 |
| Non-resident return (BNI) for income 2025 | File through MyMinfin or on the paper form | Within the period printed on the form, which must be at least one month from sending the form or making the electronic return available. The date for income 2025 is under "Not yet confirmed" in Sources | Art. 308, §1, second paragraph WIB 92 |
| Exit tax on financial assets, move to EU/EEA or a treaty state with information exchange and recovery assistance | Automatic payment deferral. Send a yearly attestation confirming the assets were not sold or pledged | Yearly; the deferral and the tax lapse 24 months after departure if the assets are not sold in that time or the person returns within 24 months | Art. 413/1, §6 WIB 92 |
| Exit tax, move elsewhere | Deferral only on request and only with adequate security. It ends if the assets are sold or pledged | Art. 413/1, §6 sets no time limit for the request | Art. 413/1, §6, third and fourth paragraphs |
| Company exit charge, EU/EEA | Choose spread payment by express request to the collector, using the official form | Within two months of the assessment notice; then a signed form each year by each due date | Art. 413/1, §§2 and 4 |
When the spread payment ends early (company). The balance falls due at the end of the month after: a move of tax residence outside the EU/EEA, a sale or a move outside the EU/EEA of all or part of the assets, dissolution (except tax-neutral mergers and divisions), insolvency, a missed instalment, a missing yearly form, or failure to provide security when asked (art. 413/1, §3).
Treaty tie-breaker. Belgium has a wide treaty network. Where a person is resident in Belgium and in another state under each state's law, the treaty's residence article decides: permanent home, then centre of vital interests, then habitual abode, then nationality, then mutual agreement. The Belgian National Register presumption does not override a treaty tie-breaker. Read the specific treaty.
Exemption or credit. For professional income (salary, self-employed profits) that a treaty lets the other state tax, Belgium generally exempts it with progression through the art. 155 reduction. For dividends, interest and royalties, relief depends on the treaty. Check each treaty.
Withholding on outbound payments. A Belgian payer withholds 30% on dividends, interest and royalties paid abroad (art. 269, §1, 1°). The rate can be reduced or removed by a tax treaty (usually through a reduced-rate claim at source or a refund) or by domestic exemptions that implement the EU Parent-Subsidiary and Interest and Royalties Directives (in the KB/WIB 92). The conditions sit with the corporate skill: see be-corporate-tax once merged.
Non-residents with Belgian employment. Belgian payroll withholding applies to pay for work done in Belgium. See belgium-payroll. Frontier and multi-state workers need the treaty with their residence state.
EU social security coordination. Social security follows Regulation (EC) 883/2004, not tax residence. A person is insured in one member state only. As a rule that is the state where they work. A worker posted to Belgium by an employer that normally operates in another member state stays in the home system if the posting is expected to last no more than 24 months and they are not replacing another posted worker (art. 12, A1 certificate). A person who normally works in two or more member states is insured in the state of residence if they do a substantial part of their work there (art. 13). The inbound tax regime does not decide social security; check the separate position of the National Social Security Office (RSZ/ONSS) on the cost allowance. Self-employed cases: see be-social-contributions.
Facts: a German engineer living in Munich (more than 150 km from the Belgian border) and never taxed in Belgium is hired directly by a Brussels company registered in the Crossroads Bank for Enterprises. He starts on 1 March 2026. His contract gives gross pay of EUR 90,000 a year. The employer also pays recurring posting costs (housing, home leave) of 35% of gross pay. The employer files the BBIB application within three months of 1 March 2026.
name: BBIB arrival 1 March 2026, gross pay EUR 90,000 a year
inputs:
annual_gross: 90000
months_worked: 10
days_in_belgium: 306
days_in_year: 365
threshold: 70000
allowance_rate: 0.35
steps:
- prorata_threshold: round(threshold * days_in_belgium / days_in_year, 2)
- gross_2026: annual_gross * months_worked / 12
- margin_over_threshold: gross_2026 - prorata_threshold
- tax_free_allowance: gross_2026 * allowance_rate
expected:
prorata_threshold: 58684.93
gross_2026: 75000
margin_over_threshold: 16315.07
tax_free_allowance: 26250
He is a Belgian resident from 1 March 2026 and taxed on worldwide income from that date. His German income for January and February is not Belgian taxable. Compute the tax itself with be-income-tax.
Facts: a Belgian resident moves her home and seat of wealth to Lisbon, Portugal, on 30 September 2026. She owns a listed share portfolio (no substantial interest) bought years ago. It was worth EUR 400,000 on 31 December 2025 and EUR 460,000 on the day she leaves. She realised no other capital gains in 2026.
name: Exit tax on financial assets, departure 30 September 2026
inputs:
value_at_departure: 460000
value_31_dec_2025: 400000
full_year_exemption: 10000
resident_months: 9
rate: 0.10
steps:
- deemed_gain: value_at_departure - value_31_dec_2025
- basic_exemption: full_year_exemption * resident_months / 12
- taxable_gain: max(deemed_gain - basic_exemption, 0)
- exit_tax: taxable_gain * rate
expected:
deemed_gain: 60000
basic_exemption: 7500
taxable_gain: 52500
exit_tax: 5250
Edge cases to check: the pro rata rounds down to the lower multiple of EUR 10 where the result is not a round figure (Circular 2026/C/74, no. 100, example 5). If she had a substantial interest, the 1.25% to 10% scale and the EUR 1 million exemption, also reduced pro rata, would apply instead (no. 51).
All read on 2026-10-22.
Not yet confirmed: the filing date printed on the 2026 non-resident return for income 2025 (art. 308 WIB 92 leaves the date to the form; FPS Finance pages at fin.belgium.be were behind a human-verification check and could not be read, and the form model in the royal decree of 22 June 2026 does not print it; secondary references give 20 November 2026); the conditions of the domestic withholding exemptions for EU parent companies and associated companies (KB/WIB 92); whether municipal surcharges apply to the exit tax in the year of departure; the RSZ/ONSS treatment of the 35% inbound cost allowance.
Contributed by Ryan Duguid.
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