Belgium · Expat tax and director pay

Up to 35% tax-free for the people you bring to Belgium, and the right pay for founders

Recruit or post staff to Belgium and you can pay them up to 35% of salary tax-free, if the employer applies within three months. Run your own Belgian company and the questions change: contributions, the minimum director pay for the 20% rate, and how profit comes out. We handle both.

Free first consultation. Fixed quote within one business day.

35%

Tax-free allowance on top of gross salary under the expat regime, with no cap since 1 January 2025

EUR 70,000

Gross annual pay that incoming taxpayers must exceed; researchers have no minimum

3 months

For the employer to apply, counted from the first day of work in Belgium

20.5%

Self-employed contributions on a director’s income up to EUR 75,024.54 in 2026

Route A · Employers and incoming staff

The special regime for incoming taxpayers and researchers

Since 1 January 2022 Belgium has two statutory regimes: incoming taxpayers (Art. 32/1 of the Income Tax Code 1992, CIR 92) and incoming researchers (Art. 32/2). You will meet them as the régime spécial d’imposition pour contribuables impatriés and chercheurs impatriés, or in Dutch as the bijzonder belastingstelsel voor ingekomen belastingplichtigen (BBIB) and ingekomen onderzoekers (BBIO).

The Law of 18 December 2025 raised the allowance from 30% to 35%, removed the EUR 90,000 cap and lowered the salary threshold from EUR 75,000 to EUR 70,000, with effect from 1 January 2025.

ConditionIncoming taxpayers, Art. 32/1Researchers, Art. 32/2
WhoEmployees, and directors who take part in day-to-day managementEmployees only; directors are excluded
Belgian employerA Belgian company, the Belgian branch of a foreign company, or a Belgian non-profit or international non-profit associationSame
How they comeRecruited directly from abroad by that employer, or seconded from abroad by a group companySame
Last 60 monthsNot a Belgian tax resident; not living within 150 km of the Belgian border; not taxed in Belgium as a non-resident on Belgian professional incomeSame
PayGross taxable pay for the Belgian work of more than EUR 70,000 a calendar year, pro-rated in the years of arrival and departure and tested every yearNo minimum
ProfileAny functionAt least 80% of working time on scientific, fundamental, industrial or technical research, and a master’s or doctorate in a listed field or 10 years of relevant experience
ApprovalA positive decision of the tax administration on the employer’s applicationSame

Nationality does not matter: a Belgian national who has lived far away for five years can qualify. Belgian rental income in the look-back period does not disqualify, as only professional income counts. The EUR 70,000 threshold applies to 2026 income.

Founders are out. The tax administration’s circular 2022/C/47 excludes directors who act within their own company as founder or co-founder, and directors who hold 30% or more of its capital. Board members who only supervise are excluded too. A founder moving to Belgium to run their own company plans on route B.
Eligibility check

Does your hire qualify?

Answer yes or no, enter the salary and see whether the regime is likely to apply, how much you can pay tax-free and how much of it still bears social security.

Borderline cases, such as a candidate who lived near the 150 km line or a director with a small stake, need a look at the documents.

1. What will the person be?

2. Who employs them in Belgium?

3. How do they come?

4. In the last 60 months, were they a Belgian tax resident?

5. In the last 60 months, did they live within 150 km of the Belgian border?

6. In the last 60 months, were they taxed in Belgium as a non-resident on Belgian work income?

7. Are they a founder or co-founder of the company, or do they hold 30% or more of its capital?

7. Will at least 80% of their working time go to research?

8. Do they hold a master’s or doctorate in a listed science field, or have 10 years of relevant experience?

When does work in Belgium start?

Taxable salary only, before the tax-free allowance.
Up to 35%, agreed in the contract on top of salary.

Indicative only, not tax advice. Based on Art. 32/1 and 32/2 CIR 92 as amended from 1 January 2025, circulars 2022/C/47 and 2026/C/51, and the social security treatment applied by the ONSS / RSZ as of November 2026. The final word is the tax administration’s decision.

What can be paid tax-free

Four items on top of salary

The allowance must be agreed and paid on top of salary: renaming part of existing pay does not work. Circular 2026/C/51 confirms that the contract does not need to name the regime.

Every month

Allowance up to 35%

Up to 35% of gross pay for the extra costs of living in Belgium, such as housing and home leave. No annual cap for pay from 1 January 2025; until 31 December 2024 it was 30%, capped at EUR 90,000.

Once, on proof

Moving costs

One house-hunting trip, travel and the move of furniture, and up to three months of hotel costs. Storage, pet transport, lease termination and losses on a sale are not covered.

First six months

Set-up costs up to EUR 1,500

Furnishing and set-up costs incurred within six months of arrival.

Families

School registration fees

Registration fees for children of compulsory school age.

Payroll reality

Tax and social security now part ways

The National Social Security Office (ONSS / RSZ) has not followed the 2025 tax changes. For social security only 30% of gross pay is exempt, up to EUR 90,000 a year. The extra 5% and anything above EUR 90,000 bear employer and employee contributions. Budget the employer cost on that basis.

Two examples with the full 35% allowance:

Gross salary EUR 150,000
Free of tax (35%)EUR 52,500
Free of social security (30%)EUR 45,000
Bears social securityEUR 7,500
Gross salary EUR 350,000
Free of tax (35%)EUR 122,500
Free of social security (30%, max EUR 90,000)EUR 90,000
Bears social securityEUR 32,500

Posted from another EU state? Under Regulation (EC) 883/2004 a posted worker can stay insured in the sending state for up to 24 months, shown by an A1 certificate issued by that state, not by Belgium; longer postings, up to five years in total, need an agreement between the two institutions. Posted employees also need a Limosa declaration. From outside the EU, a bilateral social security treaty applies where one exists; otherwise Belgian social security applies in full.

How the application works

The employer files, within three months

The employee cannot apply alone. There is no state fee.

1Before signing

Check and prepare

We test the conditions, including the 150 km and founder rules, and write the allowance into the contract on top of salary.

2Day 1

Work starts

The three-month clock starts on the first day of work in Belgium.

3Within 3 months

Application filed

The employer, or the company for a director, files the official form with the employee’s signed consent, to impatriates@minfin.fed.be or through MyMinfin.

4Within 3 months

Decision

An approval applies from the first day of work. Each year by 31 January the employer files the list of beneficiaries.

Five years, plus three

The regime lasts up to five years and can be extended once by three years if the conditions are still met; the extension is requested within three months after the first five years end. A new employer applies again, and the total stays capped at eight years.

Resident or non-resident

Beneficiaries are taxed under the normal residence rules. A non-resident beneficiary provides a yearly certificate of tax residence from the home state. The old regime for foreign executives under the 1983 circular ended on 31 December 2023.

Route B · Founders and directors

Paying yourself through a Belgian company

A founder who runs their own Belgian company is outside the expat regime. The planning sits elsewhere: director status and contributions, the minimum pay that keeps the 20% corporate rate, and how profit reaches you.

  • ✓

    A director, not an employee

    In an SRL, directors may not be bound to the company by an employment contract in that capacity, and a director can be a natural or a legal person (Art. 5:70 Companies and Associations Code). That is how a management company (société de management / managementvennootschap) can hold the mandate.

  • ✓

    Self-employed for social security

    A director of a Belgian company is generally treated as self-employed and joins a social insurance fund for the self-employed (caisse d’assurances sociales / sociaal verzekeringsfonds) when the mandate starts. Contributions are paid quarterly.

  • ✓

    Taxed as professional income

    Director pay (rémunération de dirigeant d’entreprise / bedrijfsleidersbezoldiging) is taxed at the progressive rates of 25% to 50%, plus the local surcharge. Net salary calculator.

  • ✓

    A management company pays its own director

    The minimum pay test applies to the company that claims the 20% rate. If your management company claims it, it must itself pay you, as a natural person, at least the minimum.

Social contributions 2026

What a self-employed director pays

Official 2026 table of the Federal Public Service Social Security, main occupation. Provisional contributions for 2026 are calculated on 2023 income, revalued, and adjusted later to actual 2026 income. The fund adds its own management fee.

The company also pays an annual company contribution (cotisation annuelle des sociétés / vennootschapsbijdrage) to the self-employed scheme.

Item, 2026Amount
Income up to EUR 75,024.5420.50%
Income from EUR 75,024.54 to EUR 110,562.4214.16%
Income above EUR 110,562.42No further contributions
Minimum per quarter, main activityEUR 890.42 (income of EUR 17,374.08)
Minimum per quarter, a starter’s first four quartersEUR 459.82
Maximum per quarterEUR 5,103.05, about EUR 20,412 a year

Insured in another EU state? With an A1 certificate from that state, Belgian contributions are not due. We coordinate it with the social insurance fund.

Director pay check

Will your company keep the 20% rate?

Enter the director’s pay and the company’s profit. You see the 2026 social contributions, whether the minimum pay test is met and what missing it would cost in corporate tax.

1. Which financial year are you planning?

2. How old is the company?

3. Who holds the shares?

A natural person; pay to several directors is not added together.
Before corporate tax.

Indicative only, not tax advice. Contributions use the official 2026 rates for a main occupation on the pay entered, treated as net taxable professional income, without the fund’s fee. Corporate tax assumes a small company meeting the other conditions for the 20% rate. The indexed amount for tax year 2027 has not been published officially; we use about EUR 50,000 and confirm the exact figure with you.

Minimum director pay

The test behind the 20% rate

A small company pays 20% corporate tax on the first EUR 100,000 of taxable profit instead of 25%. From its fifth taxable period it keeps that rate only if it pays at least one company director enough. The Law of 15 July 2026 reforming personal income tax changed the amount from tax year 2027.

Up to tax year 2026From tax year 2027
AmountEUR 45,000 a year to at least one directorA base amount of EUR 25,000 in the law, indexed every year and rounded to the nearest EUR 1,000: about EUR 50,000 for tax year 2027
If pay is lowerThe 20% rate still applies if the taxable profit does not exceed that paySame
From whenFifth taxable period after incorporationSame
Benefits in kindNo separate testThe 20% rate is also lost if benefits in kind make up an excessive part of the director’s pay, as defined in Art. 2 §1, 25° CIR 92

For a company whose financial year is the calendar year, tax year 2027 is the financial year 2026: plan 2026 director pay on the new amount. The other conditions stay: the company is small under Art. 1:24 of the Companies and Associations Code (no more than one of 50 staff, EUR 11,250,000 turnover and EUR 6,000,000 balance-sheet total exceeded), companies do not hold 50% or more of its shares, and it is not a financial holding or investment company.

Getting profit out

Salary, dividend or reserve

Each route out of the company has its own rate. Before any dividend the SRL must pass the net-asset test and the twelve-month liquidity test.

Dividend and reserve rates as set by the Programme Law of 30 May 2026.

RouteRateConditions
Director pay25% to 50% income tax, plus local surcharge and social contributionsCounts towards the minimum pay for the 20% corporate rate
Ordinary dividend30% withholding taxAfter corporate tax and the distribution tests
VVPRbis dividend20% on profit of the second financial year after the contribution; 18% from the third, on dividends attributed or made payable from 1 July 2026 (15% before)New registered shares issued for cash from 1 July 2013 by a company that was small at the time, fully paid up
Liquidation reserve (réserve de liquidation / liquidatiereserve)10% separate tax when booked; on a distribution, 30% within three years or 9.8% after three years, for reserves of financial years closing on or after 31 December 2025Small companies only. Older reserves keep their lower rates. Restarting a similar activity as director soon after a liquidation can cost the liquidation exemption

Planning a holding above your operating company? See Belgian holding company.

Directors who live abroad

A Belgian company, a director elsewhere

Tax

Non-resident income tax

Pay from a Belgian company is taxed in Belgium under non-resident income tax (impôt des non-résidents / belasting der niet-inwoners). The company withholds professional withholding tax (précompte professionnel / bedrijfsvoorheffing) and the director files a yearly non-resident return. How board fees and pay for day-to-day management are treated depends on the tax treaty.

Surcharge

The 7% surcharge

Non-residents pay a fixed 7% surcharge instead of the municipal surcharge residents pay. On 12 March 2026 the Court of Justice of the EU held in Chefquet (C-119/24) that it infringes the free movement of workers where it can exceed the municipal tax of comparable residents. The law has not been changed yet; affected non-residents can object or ask for ex officio relief, citing the judgment.

Social security

Self-employed in Belgium by default

A director of a Belgian company is presumed self-employed in Belgium, unless an A1 certificate from another EU or EEA state or Switzerland, or a treaty certificate, puts them under another country’s scheme.

Minimum pay

Residence is not required

A non-resident director can be the one whose pay meets the minimum for the 20% rate.

Expat regime

Open to hired directors

A non-resident director in day-to-day management can use the regime if they are not a founder or 30% shareholder, with a yearly residence certificate from the home state.

Permit

Non-EU directors working in Belgium

A non-EU national managing a Belgian company as self-employed in Belgium generally needs a professional card (carte professionnelle / beroepskaart) first. Residence and work permits.

Is it right for you?

When this pays off, and when it does not

A good fit if

  • ✓

    You hire a specialist from far abroad

    Pay above EUR 70,000, recruited directly or moved within your group: up to 35% on top, tax-free, for up to eight years.

  • ✓

    You recruit researchers

    With a qualifying degree or ten years of experience there is no salary minimum.

  • ✓

    You run your own Belgian company

    Director pay planned against the minimum, contributions budgeted, and profit taken out by the cheapest route the rules allow.

Probably not for you if

  • ✕

    Your hire lived near Belgium

    Within 150 km of the border in the last 60 months rules them out. That covers much of the Netherlands, Luxembourg, western Germany, northern France and south-east England.

  • ✕

    You want the expat regime in your own company

    Founders, co-founders and 30% shareholders are excluded. Route B applies instead.

  • ✕

    Work started more than three months ago

    If nobody applied in time, the deadline for this employer has passed.

  • ✕

    Nobody will draw real pay

    Without director pay at the minimum, the 20% rate falls away from year five. A pure holding may sit better elsewhere: Belgian holding company.

What we do for you

From the first check to the yearly filings

One team for the hires and the founders, working with your payroll provider and accountant. The fee is fixed before we start.

  • ✓

    Eligibility memo per hire

    Look-back, 150 km, recruitment route, salary and founder tests, in writing.

  • ✓

    Contract and allowance clause

    Salary and allowance split so the allowance is genuinely paid on top.

  • ✓

    Application file

    Official form, signed employee consent, filing by e-mail or MyMinfin within three months.

  • ✓

    Payroll set-up and yearly list

    Tax at 35%, social security at 30% and EUR 90,000; the 31 January list; the extension in year five.

  • ✓

    Postings and social security

    A1 certificates, Limosa declarations and treaty certificates.

  • ✓

    Director set-up

    Social insurance fund, quarterly contributions and the company contribution.

  • ✓

    Director pay plan

    Minimum pay, benefits in kind, VVPRbis and the liquidation reserve, year by year.

  • ✓

    Non-resident directors

    Withholding, the non-resident return, the treaty check and an objection after Chefquet where it fits.

How we work

Four steps, a fixed price

1Day 1

Tell us the case

Who is coming, from where, at what pay; or how your company pays you today.

2Day 1–2

Fixed quote

Scope, timeline and document list in writing.

3Weeks 1–2

Check and prepare

Eligibility memo, contract clauses, pay plan and the application file.

4Ongoing

File and follow up

Application within three months, yearly lists and returns, the extension in year five.

Your case

Bringing people to Belgium, or paying yourself there?

Tell us who is moving, from where and at what salary, or how your Belgian company is owned and pays its director. We send a fixed quote and tell you plainly if the regime will not apply or if another country fits better.

FAQ

Questions clients ask first

Can a founder use the expat regime in their own Belgian company?+

Generally no. The tax administration’s circular 2022/C/47 excludes directors who act within their own company as founder or co-founder, and directors holding 30% or more of its capital. Hired executives and staff seconded within a group can use it; a founder plans director pay through the company instead.

Does the tax-free allowance count towards the EUR 70,000 threshold?+

No. The threshold is tested on gross taxable pay for the Belgian work, so the tax-free allowance is not part of it. The pay must exceed EUR 70,000 a calendar year, pro-rated in the years of arrival and departure, and it is tested every year; failing it ends the regime. Researchers have no threshold.

Our candidate lives in the Netherlands. Can they qualify?+

Only if they did not live within 150 km of the Belgian border at any point in the 60 months before starting work in Belgium. Most of the Netherlands lies inside that distance, as do Luxembourg, western Germany, northern France and south-east England.

Who applies, and by when?+

The employer, or the company for a director, within three months of the first day of work in Belgium, using the official form with the employee’s signed consent, sent to impatriates@minfin.fed.be or through MyMinfin. The administration decides within three months, and an approval applies from the start of work. There is no state fee.

Is the 35% allowance also free of social security?+

Only in part. The ONSS / RSZ still exempts 30% of gross pay, up to EUR 90,000 a year. The extra 5%, and anything above EUR 90,000, bears employer and employee social security contributions.

How long does the regime last?+

Up to five years, extendable once by three years if the conditions are still met, so eight years at most. A new employer must apply again, within the same overall limit.

How much must a director earn for the company to keep the 20% rate?+

Up to tax year 2026, at least EUR 45,000 a year to one director. From tax year 2027, a base amount of EUR 25,000 indexed every year, about EUR 50,000 for tax year 2027. If the taxable profit is lower than the pay, the rate still applies. The test starts in the fifth taxable period, and from tax year 2027 the rate is also lost if benefits in kind make up an excessive part of the director’s pay.

VVPRbis dividend or liquidation reserve?+

It depends on the shares and the timing. VVPRbis needs new shares issued for cash from 1 July 2013 by a small company; dividends are taxed at 18% from the third financial year, for dividends attributed or made payable from 1 July 2026. A liquidation reserve costs 10% when booked and 9.8% on a distribution after three years, for reserves of financial years closing on or after 31 December 2025. We compare both on your figures.

I live abroad and direct a Belgian company. Where am I taxed?+

Pay from the Belgian company is taxed in Belgium under non-resident income tax, with professional withholding tax deducted by the company, subject to the tax treaty with your home state. Non-residents also pay a fixed 7% surcharge, which the Court of Justice of the EU held contrary to EU law in Chefquet on 12 March 2026; the law has not been changed yet.

How much does it cost?+

The fee depends on the number of people and the work involved. We send a fixed quote after a short call, and it does not change once we start. The tax administration charges no fee for the expat regime application.