Federal budget agreement: first key measures

VVPRbis / liquidation reserves

The regimes allowing small companies to distribute dividends at a reduced rate of 15 % (recently amended since last summer) will once again be subject to changes.

At present, a VVPRbis dividend is subject to a withholding tax rate of 15 %. This rate will be increased to 18 % in the future.

Liquidation reserves (= reserves created subject to the payment of an anticipatory levy of 10 %) can currently be distributed at a withholding tax rate of 5 % or 6.5 %. This levy will be increased so that the total tax burden upon distribution also amounts to 18 %.

For VVPRbis dividends, the increase would take effect as from the moment the law is adopted by the Chamber of Representatives. This is unlikely to be the case by 1 January 2026. As a result, no transitional regime is foreseen for this type of dividend. Companies wishing to secure the reduced rate of 15 % are therefore advised to distribute dividends in 2025.

With regard to liquidation reserves, the intention is to apply the increase to reserves created as from 31 December 2025. Liquidation reserves created up to and including 30 December 2025 will therefore still be eligible for distribution at a withholding tax rate of 5 % or 6.5 %.

VAT rates

The standard VAT rate of 21 % will not be increased. Nor will there be any harmonisation of the 6 % and 12 % rates to a single rate of 9 %. However, a number of products and services will be subject to higher VAT rates:

• Take-away food, hotel accommodation, campsites, sports and leisure: from 6 % to 12 %

• Pesticides: from 12 % to 21 %

The entry into force of these increased rates would be postponed until 1 March 2026.

Natural gas and electricity

Individuals who cook and heat using natural gas will face higher costs in the future, as excise duties on natural gas will increase. Excise duties on electricity, on the other hand, will be reduced. As VAT is always calculated on the price inclusive of excise duties, this indirectly implies an increase in the (nominal) VAT due on natural gas.

Tax on securities accounts

The tax on securities accounts currently amounts to 0.15 % of the average value of securities accounts exceeding € 1 million. This tax will be doubled to 0.30 %.

Lump-sum expense deduction for copyright income

Copyright income is currently subject to a withholding tax rate of 15 % (+ municipal surcharges). On the first income bracket of € 20,100, a lump-sum expense deduction of 50 % can be applied, reducing the effective tax burden (excluding municipal surcharges) to 7.5 %. On the bracket between € 20,100 and € 40,190, a lump-sum expense deduction of 25 % applies, resulting in an effective tax burden of 11.25 % on that portion.

This lump-sum expense deduction would be abolished, meaning that only actual expenses could still be deducted.

Other new or increased taxes

In addition, several other taxes would be increased or introduced:

• a “parcel tax” of € 2 on orders from non-European webshops;

• an increase in the aviation tax from € 5 to € 10 for short-haul flights;

• an increase in the insurance tax on non-life insurance from 9.25 % to 9.6 %;

• a new bank tax.

Further details on these measures, as well as on a number of other long-anticipated measures, are expected to be clarified in the coming days, including:

• capital gains taxation on the sale of financial fixed assets;

• the minimum remuneration in companies to qualify for the reduced corporate tax rate of 20 %;

• taxation on the sale of RDT (DBI) funds;

• …

Latest update: 15/12/2025