Belgium has, since 1 January 2022, implemented a new specific tax regime for foreign workers and researchers who come to settle in Belgium. The objective is to attract and retain international, qualified profiles by offering a more favourable tax framework.
Since 2022 a Belgian employer may pay part of the remuneration in the form of a reimbursement of costs proper to the employer (expenses related to expatriation), exempt from Belgian tax and social security contributions, within certain limits.
What changes as of 1 January 2025
A law published at the end of December 2025 (applicable retroactively from 1 January 2025) introduced several important relaxations:
- Increased proportion: the exempt expenses may now represent up to 35% of the gross salary (instead of 30% previously).
- Removal of the annual cap: the absolute cap of EUR 90,000 is removed. The limit is now only proportional (35%), without a maximum amount.
- Reduced salary threshold: for expatriates (excluding researchers), the required minimum gross annual salary is reduced from EUR 75,000 to EUR 70,000 per year.
Transitional rules for hires in 2025
Good news for employers who recruited in 2025: workers hired in 2025 with a gross annual salary between EUR 70,000 and EUR 75,000, and meeting the other conditions of the regime, can still submit an application.
Exceptional deadline: the application may be submitted within three months from 9 January 2026.
Attention: social security does not (yet) follow
Important point to anticipate: the social security rules have not been adapted at this stage. The social authorities will continue to apply the rules in force since 2022.
Consequence: amounts exempt for tax purposes may remain subject to social security contributions. This creates a mismatch between taxation and social security, and therefore increased complexity for employers.
Several market players, including BDO, have reported this inconsistency to the authorities and requested alignment of the rules. To date, no adaptation has yet been confirmed.
Practical points of attention for employers:
Companies that already apply this regime should:
- update employment contracts and/or addenda,
- adapt the remuneration structure,
- clarify the social treatment of allowances.
An individual analysis remains indispensable to:
- secure the application of the regime,
- avoid subsequent reassessments,
- optimise the overall employer cost.
In conclusion, these adjustments strengthen Belgium’s fiscal attractiveness for international talent. However, the absence of alignment with social security still limits the real impact of the scheme and calls for cautious implementation. BDO’s international mobility teams are closely monitoring these developments and can assist you with the analysis and operational implementation of the regime.
Nicolas Stockmans, Partner, Global Mobility Services - BDO
Melissa Claessens, Senior Manager, Global Mobility Services - BDO
