Latest news & developments
Antwerp Court of Appeal rules capital gains on carry shares from option exercises as non-taxable income
On 25 February 2025, the Antwerp Court of Appeal confirmed that capital gains on shares – issued by Co-Investment Vehicles (CIVs) – embedding a carried interest and acquired following the exercise of options that were taxable at grant are not taxable as miscellaneous income (art. 90 1° ITC 92 and 90 9° ITC 92) (2023/AR/1737).
Tax Bites Podcast – Amended penalty regime for first offence
Tax Bites Podcast on tax dispute mitigation With this podcast we kick off a series of podcasts on topics related to tax audits. In this first podcast we discuss the recent amendment to the penalty regime applicable to a first offence. Pieter interrogates his guests on the implications of this amendment and what this means
Tax Bites Podcast – DAC6
The mandatory disclosure rules, commonly known as DAC6, have been in place since 2020. There is a renewed focus on this legislation. The EU is looking into an update of the hallmarks, potentially including the Unshell Directive proposal in the hallmarks, and even countries are seeing the benefits of DAC 6 and consider introducing DAC6
Belgian Tax Authorities push hard on Co-Operative Tax Compliance Programme (CTCP)
The CTCP: A Growing pillar in Belgian tax compliance The Belgian Tax Authorities (BTA) are intensifying their efforts to promote the Belgian Co-operative Tax Compliance Programme (CTCP), marking an important shift in the tax compliance landscape for large and very large enterprises in Belgium. The Belgian CTCP aims to address the corporate need for a
Royal Decree grants temporary extension for investment deduction certificate
To ease the transition to the new ‘thematic’ investment deduction regime, the Belgian government has issued a Royal Decree dated 28 July 2025 (Dutch/French) introducing a temporary transitional (one-off) extension to the certificate application deadline, allowing taxpayers to safeguard their entitlement to the deduction. Under the law of 12 May 2024, taxpayers must obtain a
Circular letter 2025/C/49 confirms the right to a first-time filing error without penalty
On 28 July 2025, the Belgian tax authorities issued a circular letter, providing guidance on the amendments to Article 444 of the Belgian Income Tax Code (WIB 92) introduced by the Programme Law of 18 July 2025. The revised rules, applicable to tax assessments issued from 29 July 2025 onwards, introduce a rebuttable presumption of
Wage withholding tax exemption – New circular letter provides an update on the partial wage withholding tax exemption for night and shift work
Context On 31 July 2025, the Minister of Finance released a long-anticipated circular letter detailing significant updates to the partial wage withholding tax exemption for night and shift work. The introduction of the Bis Variant, coupled with recent case law, contributed to increased complexity, and varied interpretations of certain regulations, leading to uncertainty among applicants.
Belgian Government Summer Agreement – 21 July 2025
On 21 July 2025, the Belgian government reached a summer agreement to implement reforms in the fields of pensions, the labour market, healthcare, and income tax. This agreement needs to be incorporated into draft legislation, which still requires approval through the legislative process. A high-level summary of the envisaged measures in the fields of
