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Jun 5 2026

Key updates to Belgium’s inbound tax regimes

Belgian Inbound Tax Regimes (BBIB & BBIO): Key updates following the 2025 law and 2026 circular

On 1 April 2026, the Belgian tax authorities published Circular 2026/C/51, providing further clarification on the changes introduced by the law of 18 December 2025. The special tax regimes for inbound taxpayers (BBIB) and inbound researchers (BBIO) were originally introduced by the Program Law of 27 December 2021 and entered into force on 1 January 2022, with the aim of increasing Belgium’s competitiveness in attracting international talent. Compared to the former expatriate tax system, these regimes provide greater legal certainty and a more transparent framework for employers and employees.

BBIB – Special Tax Regime for Inbound Taxpayers

The BBIB regime applies to employees and certain company directors who are recruited from abroad or assigned within a group. It requires an annual gross salary of more than EUR 70,000 (taxable in Belgium). During the 60 months prior to the start of employment in Belgium, the individual must not have been a Belgian tax resident, must not have been subject to Belgian non-resident income tax on Belgian professional income, and must not have lived within 150 km of the Belgian border.
The application must be submitted by the employer within three months of the employment start date. Once granted, the regime applies for a period of five years and may be extended by three additional years.

BBIO – Special Tax Regime for Inbound Researchers

The BBIO regime applies only to employees performing research activities. It requires either a relevant master’s or doctoral degree, or at least 10 years of relevant professional experience. The employee must work in a laboratory or in an undertaking carrying out research and development (R&D) programmes, with at least 80% of working time dedicated to research activities. The general BBIB conditions apply, except that no minimum salary requirement is imposed.

Changes applicable as from 1 January 2025

As from 1 January 2025, the following changes apply retroactively: the maximum percentage of costs proper to the employer increases from 30% to 35%, the maximum annual ceiling of EUR 90,000 for such costs is abolished (for tax purposes), and the minimum annual gross salary threshold for inbound taxpayers is reduced from EUR 75,000 to more than EUR 70,000.

Clarifications from the circular

The circular specifies that, where the employer chooses to implement these changes, the employment contract must be amended within the prescribed deadline, no later than the end of June 2026. In case of retroactive application, the 2025 tax forms (fiche 281.10), individual accounts and withholding tax returns must be corrected. Employers may also decide to apply the changes only as from 1 January 2026.

Technical note (social security)

The increase to 35% and the removal of the ceiling apply for tax purposes. Different rules may continue to apply for social security purposes.

Source: content provided by the experts at Boxx Global Expat Solutions

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Key updates to Belgium’s inbound tax regimes

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