Belgian Tax Authorities Clarify Retroactive Changes to Expat Regime, Opening New Window for Inbound Talent

On 14 April the Belgian Ministry of Finance issued Circular 2026/C/51, finally answering the practical questions that have dogged employers since Parliament retroactively overhauled the Special Tax Regime for Inbound Taxpayers and Researchers late last year. The regime—popular with multinationals for capping taxable salary and allowing a tax-free employer reimbursement—was tweaked to raise the exemption ceiling from 30 % to 35 %, abolish the €90,000 cap and lower the minimum salary threshold from €75,000 to €70,000, all with effect from 1 January 2025. The circular confirms that employees who took up Belgian assignments between 1 January 2025 and 9 January 2026 but were initially excluded because they earned between €70,000 and €75,000 can now apply retroactively—provided the application was (or is) filed by 9 April 2026. Employers may also rewrite contracts within three months (deadline 1 July 2026) to reflect the higher 35 % reimbursement and then correct payroll filings for 2025. For mobility teams the message is two-fold: act fast and involve payroll early. Companies that fail to amend contracts or resubmit withholding forms risk forfeiting thousands of euros per assignee in tax savings and may face penalties for late filings. On the upside, the clarified rules allow HR to restructure compensation packages to keep Belgium competitive with the Netherlands and Germany for mobile talent, while still meeting cost-control targets. Tax advisers note that lowering gross salary to keep total cost neutral—while boosting the tax-free allowance—could affect pension accruals and bonus benchmarks. They recommend modelling net-to-gross scenarios and documenting works-council consultations where required.



For companies seeking a seamless way to manage the visa and residence-permit paperwork that inevitably accompanies these tax-driven moves, VisaHQ can step in as a one-stop partner. The platform’s Belgium portal (https://www.visahq.com/belgium/) lets HR teams and individual assignees check requirements, track applications and obtain expert support, reducing administrative strain while the payroll department focuses on implementing the new 35 % regime.

Any contractual changes must also respect Belgian labour-law limits on retroactive amendments. The circular is a welcome piece of certainty for multinationals planning 2026 head-count moves to Brussels, Antwerp or Ghent. With fierce regional competition for researchers and tech specialists, Belgium’s clarified expat rules remove a major planning obstacle just as the EU’s digital-visa and EES roll-outs add friction on the travel side of the mobility equation.