VAT exemption for financial intermediation: broader than you think
Versãofast (GC, 26 Nov 2025, T-657/24): a functional test. The recent Versãofast judgment (26 November 2025, General Court) clarifies the scope of the VAT exemption for credit intermediation. While the Court recalls that VAT exemptions must be interpreted strictly, it adopts a functional approach to “intermediation”, focusing on what the service enables rather than on
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
Simplified side stream mergers – new law clears hurdles for ‘real’ tax neutrality
On 16 June 2023, the ‘simplified side stream merger’ (vereenvoudigde zusterfusie / fusion simplifiée entre soeurs) was introduced in the Code of Companies and Associations and in the Income Tax Code. However, even in case all conditions were fulfilled, the transaction could not entirely take place tax neutrally due to ‘imperfections’ in the corporate income
The first tax measures of the new government adopted
On 17 July 2025, the Chamber adopted a first set of tax measures. The other measures included in the Easter agreement are part of the draft law containing various provisions, which is currently under review at the Chamber. The main measures adopted are as follows: From a corporate tax and and employer perspective: Participation exemption
Future capital gains tax on the sale of shares of companies: complexity around the valuation of the company
As widely known by now, the budget note from De Wever I includes a capital gains tax on shares. Although not many details are known yet, the note stipulates that there will be a general solidarity contribution on the future realized capital gains of financial assets, accrued from the moment of the introduction of the
Tax Bites podcast – Belgium’s new government agreement: First insights
Welcome to our Tax Bites podcast series. In this episode, we bring together several colleagues who have closely monitored the recent Belgian government negotiations. Join us as we delve into the newly agreed measures at the Belgian government level. About the speakers Bart Van den Bussche Willem Vandromme Véronqiue De Brabanter Pieter Déré (Host) Missed
De Wever I – Federal government agreement – Main considerations from a tax perspective
Further to the new Belgian federal government agreement which was reached on 31 January 2025, various new tax measures and related changes can be expected soon. Hereafter we will provide you with a (non-exhaustive) overview of the key changes included in said agreement. Note that all of these announced measures can still be subject to
New Belgian Federal Government Agreement and Upcoming Tax Reform and its impact on Entrepreneurship & Economic Climate in Belgium
On January 31, 2025, Belgium presented a new federal government agreement announcing major tax policy changes that will affect entrepreneurship and competitiveness. Some first key highlights based on the info currently available: Competitiveness: labour costs for low and middle incomes will be reduced, but the impact might be mitigated due to updated compensation practices related
