Belgium’s Chamber of Representatives has passed the long-awaited ‘Second Programme Law’, a package of fiscal measures that includes sweeping improvements to the inbound expatriate tax regime. Voted through on 12 December 2025, the legislation will be published in the Belgian Official Gazette before year-end and most provisions apply retroactively from 1 January 2025.
Background and key changes
Belgium replaced its 40-year-old special expatriate scheme with a more restrictive system in 2022. Take-up plunged: only about 2,400 workers qualified in 2024 versus more than 8,000 under the previous rules. Multinationals warned that the higher salary bar (€75,000) and the absolute cap of €90,000 on the tax-free cost-of-living allowance made Belgium less competitive against the Netherlands, France and the UK. The new law addresses those concerns by:
• Lowering the minimum gross annual salary from €75,000 to €70,000;
• Raising the employer “expenses proper” allowance from 30 % to 35 % of gross pay and abolishing the €90,000 ceiling;
• Allowing companies three months from the Gazette publication to file an application so employees hired earlier in 2025 can benefit retroactively.
Practical implications for employers
HR and global-mobility teams should revisit pending or rejected applications: workers who narrowly missed the €75,000 threshold may now qualify. The higher 35 % allowance can materially reduce payroll cost projections for long-term assignments. Employers must, however, amend shadow-payroll calculations quickly to avoid end-of-year withholding errors. Tax advisers expect the authorities to issue updated circulars clarifying documentation requirements for the enlarged allowance.
![Belgian Parliament Approves Law Easing Expat Tax Regime, Lowering Salary Threshold to €70,000]()
In parallel, VisaHQ’s Belgium portal (https://www.visahq.com/belgium/) offers companies and assignees an easy way to manage the visa and residence-permit formalities that accompany any cross-border move, providing step-by-step guidance, document checklists and real-time application tracking so the administrative side keeps pace with the new tax incentives.
Competitive positioning
By widening eligibility and removing the hard cap, Belgium aims to reclaim regional attractiveness for shared-services centres, R&D hubs and EU headquarters staff. The move aligns Belgium more closely with the Dutch ‘30 % ruling’—still considered the benchmark in Benelux—while preserving strict residency-history rules (no Belgian tax residence or work within 60 months prior to arrival). Companies comparing relocation destinations will need to model the net-salary effect carefully: Belgium’s top marginal rate remains 50 %, but the larger tax-free component narrows the gap.
What’s next
The law will enter into force 10 days after its publication; the Ministry of Finance is expected to release a FAQ shortly thereafter. Mobility managers should prepare communication campaigns for affected employees and ensure payroll providers can process retroactive corrections. Failure to apply within the three-month window could forfeit the benefit for 2025, so prompt action is crucial. The government has signalled that a broader personal-tax reform is slated for mid-2026, which may further influence assignment-cost modelling.
Bottom line
The parliamentary vote is a major win for employers lobbying for a more competitive environment. By easing salary thresholds and boosting the tax-free allowance, Belgium is sending a clear signal that it wants to remain an attractive hub for international talent and regional headquarters.
Background and key changes
Belgium replaced its 40-year-old special expatriate scheme with a more restrictive system in 2022. Take-up plunged: only about 2,400 workers qualified in 2024 versus more than 8,000 under the previous rules. Multinationals warned that the higher salary bar (€75,000) and the absolute cap of €90,000 on the tax-free cost-of-living allowance made Belgium less competitive against the Netherlands, France and the UK. The new law addresses those concerns by:
• Lowering the minimum gross annual salary from €75,000 to €70,000;
• Raising the employer “expenses proper” allowance from 30 % to 35 % of gross pay and abolishing the €90,000 ceiling;
• Allowing companies three months from the Gazette publication to file an application so employees hired earlier in 2025 can benefit retroactively.
Practical implications for employers
HR and global-mobility teams should revisit pending or rejected applications: workers who narrowly missed the €75,000 threshold may now qualify. The higher 35 % allowance can materially reduce payroll cost projections for long-term assignments. Employers must, however, amend shadow-payroll calculations quickly to avoid end-of-year withholding errors. Tax advisers expect the authorities to issue updated circulars clarifying documentation requirements for the enlarged allowance.
In parallel, VisaHQ’s Belgium portal (https://www.visahq.com/belgium/) offers companies and assignees an easy way to manage the visa and residence-permit formalities that accompany any cross-border move, providing step-by-step guidance, document checklists and real-time application tracking so the administrative side keeps pace with the new tax incentives.
Competitive positioning
By widening eligibility and removing the hard cap, Belgium aims to reclaim regional attractiveness for shared-services centres, R&D hubs and EU headquarters staff. The move aligns Belgium more closely with the Dutch ‘30 % ruling’—still considered the benchmark in Benelux—while preserving strict residency-history rules (no Belgian tax residence or work within 60 months prior to arrival). Companies comparing relocation destinations will need to model the net-salary effect carefully: Belgium’s top marginal rate remains 50 %, but the larger tax-free component narrows the gap.
What’s next
The law will enter into force 10 days after its publication; the Ministry of Finance is expected to release a FAQ shortly thereafter. Mobility managers should prepare communication campaigns for affected employees and ensure payroll providers can process retroactive corrections. Failure to apply within the three-month window could forfeit the benefit for 2025, so prompt action is crucial. The government has signalled that a broader personal-tax reform is slated for mid-2026, which may further influence assignment-cost modelling.
Bottom line
The parliamentary vote is a major win for employers lobbying for a more competitive environment. By easing salary thresholds and boosting the tax-free allowance, Belgium is sending a clear signal that it wants to remain an attractive hub for international talent and regional headquarters.
