A number of measures have already been discussed in our previous news items in a substantive and critical analysis:
- Exit tax on the emigration of companies: text approved by the Finance Committee;
- Arizona coalition agreement: expected tax reforms
Initially, the Programme Law was scheduled to enter into force on 1 July 2025. However, the request for advice from the Council of State and the submission of a number of amendments blocked the vote at the end of June, which also delayed the entry into force.
The parliamentary process has now been completed and the law was published on 29 July 2025 in the Belgian Official Gazette. Contrary to what was initially planned, most of the measures will enter into force on the date of publication in the Belgian Official Gazette.
For example, the exit tax on the emigration of companies at shareholder level will apply to transactions from 29 July 2025 (for more information, please refer to our previous news item on this subject).
The amendments to the VVPR-bis regime and the liquidation reserve system has also entered into force on the date of publication of the Programme Law in the Belgian Official Gazette, i.e. on 29 July 2025 (for more information, please refer to our previous on this subject). It is important to note in this regard that existing liquidation reserves that have been retained for less than 5 years but more than 3 years as of 29 July 2025 may also be distributed early at a rate of 6.5%. For companies that keep accounts on a calendar year basis, this specifically concerns liquidation reserves created for the financial years 2020 (tax assessment year 2021) and 2021 (tax assessment year 2022). The companies concerned will also retain the option of distributing these liquidation reserves after five years at the ('old') rate of 5% (i.e. at the earliest in 2026 for liquidation reserves set aside for the 2020 financial year and at the earliest in 2027 for liquidation reserves set aside for the 2021 financial year). For the sake of completeness, it should be noted that the tax return forms (which take into account the adjusted rates) are not yet available.
The carried interest reforms also apply to income paid or allocated from 29 July 2025 onwards. The restriction on the creation of liquidation reserves for a company that holds shares or units in a carried interest vehicle (which is already applied in practice by the Ruling Commission) and the tightening of the participation requirement for the DBI deduction will take effect from the 2026 tax year. The substance of these reforms has also been explained in our previous news items.
If you have any questions about the measures, please do not hesitate to contact us.
