Higher tax on VVPRbis and liquidation reserves: distributing profits quickly at more favourable rates?
January 2026 - The federal budget agreement of November 2025 announced that the tax burden on dividend distributions relating to VVPRbis and liquidation reserves will increase from 15% to 18%. This measure puts pressure on the tax-friendly distribution of accumulated profits. What exactly is changing, and does it (or did it) still make sense to take action before the end of 2025?
Why VVPRbis and liquidation reserves are so popular
VVPRbis and liquidation reserves were created to give SMEs the opportunity to distribute their profits at a lower rate. With VVPRbis, this is done through a reduced withholding tax on dividends, while with liquidation reserves, an anticipatory tax is paid first and then, upon distribution, a limited additional tax.
Due to these favourable rates, both systems were used extensively, especially in management companies. This is precisely why the federal government is now looking at these regimes as a way to generate additional revenue.
What has already changed through the Programme Law
The Programme Law of July 2025 already brought some important changes, especially with regard to liquidation reserves. For reserves created from 1 January 2026 onwards, the waiting period was reduced from five to three years. At the same time, the withholding tax on distributions rose from 5% to 6.5%, bringing the total tax burden to 15%.
Anyone who distributes liquidation reserves earlier than after three years will now pay 30% withholding tax. For reserves created no later than 31 December 2025, a transitional arrangement with options applies, but here too the system has become more complex.
New budget plans: increase to 18%
In the budget agreement of November 2025, the De Wever government went one step further. For both VVPRbis and liquidation reserves, the total tax burden would increase to 18%.
For VVPRbis, the new rate would apply from the publication of the law in the Belgian Official Gazette. As this publication is not expected to take place until early 2026, the 15% rate will remain in force for the time being.
In the case of liquidation reserves, a clear distinction is made. Reserves created by 30 December 2025 at the latest would still be eligible for the existing rates. For reserves accumulated from 31 December 2025 onwards, the withholding tax would increase to 9.8%, bringing the total tax burden to 18% as well.
It is striking that this approach once again increases the differences between VVPRbis and liquidation reserves, whereas the previous focus was on harmonisation. Moreover, the scheme has not yet been laid down in law, which means that changes cannot be ruled out.
Paying dividends quickly: a good idea or not?
Many entrepreneurs are wondering whether it would be beneficial to pay an interim dividend before the end of 2025 in order to be sure of the lower rate of 15%. In some cases, this may be a wise move, but it is not an automatic decision.
A dividend payment reduces the company's equity capital. This may have consequences for the new capital gains tax that will come into effect on 1 January 2026. After all, the value of the shares on 31 December 2025 will be the benchmark. The lower that value, the higher the taxable capital gain on a subsequent sale.
In addition, a dividend payment may result in a company being considered a financial company, for example if it holds a significant share portfolio. In that case, it loses the right to the reduced corporation tax rate, which can cost up to 5,000 euro per year.
Current account positions also deserve attention. Due to a decrease in reserves, interest on a high credit current account may later be reclassified as dividends, resulting in higher taxation.
Finally, the liquidity position is also crucial. If the company has to borrow in order to pay a dividend, the interest on that loan is generally not deductible.
