Belgium: Does nationalization affect the tax treatment of a cross-border pension?

This article outlines the Belgian tax risks of foreign pension contributions for cross-border workers, including potential economic double taxation, and explains how a recent Dutch “balance scheme” decision may offer relief.

Belgium has taken further steps in the implementation of the OECD/G20 Pillar 2 rules with the publication of the draft Income Inclusion Rule (IIR) return and accompanying draft instructions, and Circular 2026/C/41 (addendum), which provides clarification on the use of exchange rates where the presentation currency of the consolidated financial statements differs from the euro.

In February 2026, the United States introduced a series of significant and fast‑moving measures that alter the trade environment for all exporters shipping goods into the country.

This article explains a recent European Court of Justice ruling on how all worldwide work activities must be considered when determining the applicable social security regime for cross-border employees under the 25% rule.

News on tax developments affecting the international Financial Services industry.

In this article, we explore the impact of recent Belgian case law on Luxembourg UCIs and their potential to reclaim subscription tax under the Belgium-Luxembourg tax treaty.

The VAT chain reform introduces new compliance measures and deadlines, impacting taxpayers starting 1 January 2025. Key changes include new filing deadlines, VAT credit management, and stricter penalties.

The European Court of Justice decided on November 7, 2024, that the levying of withholding taxes on dividends received by foreign insurance companies on their investments relating to unit-linked insurance policies can violate EU law.

The Belgian tax authorities (FPS Finance) announced that from 2 September 2024 multinational enterprises (MNE) and large domestic groups subject to the minimum tax for MNE groups and large domestic groups (Pillar 2) can start their Pillar 2 related prepayments.

The Belgian government submitted its proposal for a mandatory B2B invoicing scheme.

The Belgian government's proposed draft program law on the cayman tax faces scrutiny for introducing extensive changes, prompting concerns about its logic, potential legal challenges, and its perceived bias towards tax authorities.

The 1 January 2022 a new expat tax regime introduced in Belgium that provides for a favourable income tax (and social security) treatment for employees, directors and researchers recruited abroad or seconded to Belgium.

A common challenge in M&A transactions is to achieve a tax-effective interest deduction with regard to the acquisition funding.

The double tax treaty between Belgium and Luxembourg gives the opportunity for Luxembourg residents to lower the Belgian withholding tax rate of 30% to 15% and even in some cases to 10% for Belgian sourced dividends.

n the context of the latest budgetary measures, a decision has been taken to intensify the taxation of the financial intermediaries (banks, insurance companies and investment undertakings). The changes are therefore aimed at the entire financial sector.

On Thursday the 27th of October 2022, the Belgian Constitutional Court has delivered its long-awaited judgment on the constitutionality of the annual tax on securities accounts introduced by the Act of February 17, 2021 (hereafter “ATSA”).

The Annual Tax on Securities Accounts (hereafter: “ATSA” – also known as de “Jaarlijkse Taks op de Effectenrekeningen”, JTER or “Taxe annuelle sur les comptes-titres”, TACT) is applicable (among other things) to securities accounts held in Belgium, even if they are held by non-Belgian residents/account holder.

The majority of the Belgian corporate (statutory) investment vehicles subject to a regulated financial regime (either UCITS or AIF) can benefit from a reduced corporate tax base.

The ELTIF is intended to promote long-term investments in the real European economy (‘Europe 2020 strategy’).

An amendment to Royal Decree no. 31 has altered the guarantee requirements for a Belgian VAT registration of a foreign taxpayer with the appointment of a fiscal representative. These changes have entered into force as of 1 October 2021.