Belgium has quietly handed multinationals an early Christmas present. A tax-alert issued on 23 December confirms that Parliament has voted through a package of amendments to the country’s ‘special tax regime for inbound employees and researchers’. The new law – back-dated to 1 January 2025 – raises the employer-reimbursable “cost-of-expatriation” allowance from 30 % to 35 % and abolishes the previous €90,000 annual cap altogether. It also lowers the minimum salary threshold for eligibility from €75,000 to €70,000. In practice this means that senior specialists earning €200,000 can now receive up to €70,000 tax-free, while mid-level profiles on €72,000 who were previously excluded can finally join the scheme.
Why it matters is two-fold. First, Belgium has been engaged in a tug-of-war for talent with neighbouring Netherlands, Luxembourg and Germany, all of which sweetened their impatriate regimes earlier this year. Payroll modelling by the Big-4 suggests the 5-percentage-point hike cuts the total employer cost of a €120,000 package by roughly €5,000 a year – enough to tilt location decisions for regional headquarters and R&D centres. Second, the text makes no change to social-security rules: the Belgian National Office of Social Security confirmed on 22 December that the old 30 %/€90,000 ceiling will still apply for social-security contributions. Companies will therefore have to run dual calculations – one for tax, one for payroll withholding – and update assignment letters accordingly.
For HR and mobility teams the retroactive element is the real headache. Employers have barely a week to adjust December payrolls so that 2025 earnings reflect the new 35 % allowance; if that is not feasible, they will have to run catch-up corrections in January and issue amended payslips. Deloitte warns that contract wording must be checked carefully because Belgian authorities insist that any cost allowance be explicitly mentioned in the employment contract or an addendum. Failing that, audits may claw back the benefit.
![Belgium boosts expat tax regime: higher allowance and lower salary threshold take retroactive effect]()
In navigating these fast-moving compliance requirements, many employers turn to VisaHQ for streamlined visa and work-permit processing. The platform’s Belgium desk (https://www.visahq.com/belgium/) accelerates document collection, tracks consular changes in real time, and can integrate with mobility policies so that newly eligible assignees obtain the right entry status before payroll adjustments kick in.
Transitional measures allow employees who started between 1 January and the publication date of the law to file a ‘late’ application within three months of Gazette publication, meaning assignees who previously missed the salary cut-off now get a second chance. Global mobility managers should therefore review all 2025 hires and researchers on Belgian assignments to identify cases that can be upgraded.
Looking ahead, Belgium’s decision sends a clear signal that it wants to stay on the short-list for high-skilled relocations despite its headline 50 % top tax rate. Yet the mis-alignment with social security is likely to resurface in 2026 bargaining rounds. Companies would be wise to budget conservatively, ensure payroll systems can handle mixed ceilings, and brief employees early to avoid ‘net pay’ surprises in the New Year.
Why it matters is two-fold. First, Belgium has been engaged in a tug-of-war for talent with neighbouring Netherlands, Luxembourg and Germany, all of which sweetened their impatriate regimes earlier this year. Payroll modelling by the Big-4 suggests the 5-percentage-point hike cuts the total employer cost of a €120,000 package by roughly €5,000 a year – enough to tilt location decisions for regional headquarters and R&D centres. Second, the text makes no change to social-security rules: the Belgian National Office of Social Security confirmed on 22 December that the old 30 %/€90,000 ceiling will still apply for social-security contributions. Companies will therefore have to run dual calculations – one for tax, one for payroll withholding – and update assignment letters accordingly.
For HR and mobility teams the retroactive element is the real headache. Employers have barely a week to adjust December payrolls so that 2025 earnings reflect the new 35 % allowance; if that is not feasible, they will have to run catch-up corrections in January and issue amended payslips. Deloitte warns that contract wording must be checked carefully because Belgian authorities insist that any cost allowance be explicitly mentioned in the employment contract or an addendum. Failing that, audits may claw back the benefit.
In navigating these fast-moving compliance requirements, many employers turn to VisaHQ for streamlined visa and work-permit processing. The platform’s Belgium desk (https://www.visahq.com/belgium/) accelerates document collection, tracks consular changes in real time, and can integrate with mobility policies so that newly eligible assignees obtain the right entry status before payroll adjustments kick in.
Transitional measures allow employees who started between 1 January and the publication date of the law to file a ‘late’ application within three months of Gazette publication, meaning assignees who previously missed the salary cut-off now get a second chance. Global mobility managers should therefore review all 2025 hires and researchers on Belgian assignments to identify cases that can be upgraded.
Looking ahead, Belgium’s decision sends a clear signal that it wants to stay on the short-list for high-skilled relocations despite its headline 50 % top tax rate. Yet the mis-alignment with social security is likely to resurface in 2026 bargaining rounds. Companies would be wise to budget conservatively, ensure payroll systems can handle mixed ceilings, and brief employees early to avoid ‘net pay’ surprises in the New Year.
