Latest news & developments
Pledged shares and the participation exemption — Antwerp Court confirms the common‑sense approach applied by the ruling commission
Based on a strict reading of the law, pledged shares are not taken into account to determine if a shareholder has sufficient participation to benefit from dividends received deduction and dividend withholding tax exemption. The administrative tolerance in this respect has recently been confirmed by the Court of Appeal of Antwerp. When a company takes out a loan to finance an acquisition, banks often require that (at least part of) the acquired shares are pledged as a collateral. Under Belgian tax law, pledged shares are not counted for
Flanders advances pay‑transparency transposition for the public sector
The Flemish Government approved a draft decree to partially implement the EU Pay Transparency Directive (EU 2023/970) for the Flemish public sector, taking effect on 7 June 2026. Scope Applies to Flemish services, local authorities, and educational institutions and their staff (public sector under Flemish jurisdiction). Right to information Employees may request written information on
Tax Bites Podcast – Inside the OECD Pillar 2 Side-by-Side package: Key features and insights
This podcast episode provides an overview of the Pillar 2 Side-by-Side agreement and its key features. We discuss the main points of the newly introduced safe harbors and highlight what listeners should watch for in the (near) future. Tune in for practical insights and essential takeaways on this important topic. Are you interested in learning more about the Side-by-Side package? Sign
Belgium partially repeals previously introduced updates to the form 275LF
On 7 December 2025, Belgium issued a new Royal Decree reversing several amendments introduced to the Belgian transfer pricing documentation forms by the Royal Decree of 16 June 2024, prior to these changes taking actual effect. Belgium’s transfer pricing documentation regime consists of the Local File Form (275 LF) and Master File (275 MF). Entities belonging to multinational groups with consolidated gross revenue of EUR
Belgium’s comprehensive capital gains tax changes: key updates and implications starting January 2026
As indicated in our Newsflash of July 8, 2025, capital gains on financial assets will become taxable as of January 1,2026. We have summed up and updated below how this capital gain tax (CGT) will work based on the latest version available. Kindly be advised that the draft legislation is expected to be published on
EUDR Newsflash: Compliance will be won or lost at the border
The recent EU vote, held just before the winter holidays and only days before the original go-live date, has resulted in a further 12-month deferral and a significant refocus for EUDR compliance. The border is now the central control point, placing importers firmly in the spotlight. The core objective of the law has not changed
New law providing various provisions – Key tax changes adopted by the Chamber
On 11 December 2025, after extensive discussions within the Finance Commission, the Chamber adopted the draft law providing various provisions. This legislation encompasses both corporate and personal income tax measures, alongside significant updates to tax procedures. From a corporate tax perspective, here are the key measures adopted: The “Sicav RDT / DBI Bevek” regime remains applicable, but a 5% tax will
Belgium’s Expat Regime – Key takeaways from the new legislation
Last Friday, the parliament approved various important tax measures, including the changes to the special tax regime for inbound employees and researchers. While the text is yet to be published in the Official Gazette, it is essential to highlight that these changes will take effect retroactively from 1 January 2025 (except for social security purposes).
