Higher Tax on VVPRbis Dividends and Liquidation Reserves: What Will Change Starting July 1, 2026?
August 2026 - If you, as an entrepreneur, distribute profits to yourself through the VVPRbis system or a liquidation reserve, you will pay a higher withholding tax starting July 1, 2026.
Through the most recent Program Act—published in the Belgian Official Gazette on June 1, 2026—the federal government has brought the tax treatment of these two preferential regimes closer together, resulting in an increase in the total tax burden to 18%. What does this mean in practice for your company and your dividend planning?
VVPRbis: withholding tax rises to 18%
The VVPRbis regime allows shareholders of certain small companies to receive dividends at a reduced withholding tax rate. After the mandatory holding period of three fiscal years, that rate was 15% for many years.
As of July 1, 2026, this rate has been increased to 18% for all dividends declared or made payable on or after that date. The holding period and the other conditions remain unchanged. The legislative amendment therefore applies exclusively to the distributions themselves, not to the shares or capital increases to which the regime applies.
Liquidation reserves are also becoming more expensive
It is not only VVPRbis that is being taxed more heavily. The withholding tax on liquidation reserves is also increasing.
For liquidation reserves set aside for fiscal years ending on or after December 31, 2025, the withholding tax will now be 9.8% instead of 6.5% after the three-year waiting period. Since a 10% advance withholding tax is already paid when a liquidation reserve is established, the total tax burden will also amount to 18%.
A transitional arrangement continues to apply to older liquidation reserves. Did you set up reserves before December 31, 2025? Depending on your situation, you can still choose between:
a distribution after three years subject to a 6.5% withholding tax
a distribution after five years subject to a 5% withholding tax
As a result, historical reserves often remain more tax-advantageous than new reserves.
What impact does this have on your business?
At first glance, the increase seems modest, but it can still make a noticeable difference on larger dividend payments. A dividend of 100,000 euros, on which a 15% withholding tax was previously due, is now taxed at 18%. That amounts to an additional tax of 3,000 euros.
For business owners who regularly withdraw profits from their company, a well-thought-out dividend strategy therefore becomes even more important. It remains worthwhile to consider:
which tax regime is most advantageous
which liquidation reserves fall under the transitional arrangement
when it is best to make a dividend payment
how dividend payments relate to other forms of compensation
The right choice depends on the company’s age, available reserves, future investment plans, and the personal financial situation of the shareholder(s).
Planning Ahead Pays Off
Under the new rules, the significant tax differences between VVPRbis and new liquidation reserves will largely disappear. Nevertheless, both systems continue to offer attractive options for distributing profits in a tax-efficient manner compared to the standard 30% withholding tax rate.
A periodic review of your dividend policy with your accountant is therefore well worth the effort. This way, you can avoid unpleasant tax surprises and ensure that your company’s profits are distributed to the shareholder(s) in the most efficient manner.
