Substantial Participation — What Changes for Major Shareholders

If you hold 20% or more of a Belgian company, the new capital gains tax applies to you. Here’s what matters.

Who is affected?

Shareholders holding 20% or more of a Belgian company — or meeting equivalent participation criteria — are subject to the substantial participation regime.

How it works

A €1 million tax-free allowance on gains applies over your lifetime. Above that threshold, progressive rates apply.

The Snapshot Rule

The valuation locked at 31 December 2025 determines your baseline.

Why act now?

Documenting your company’s value before the deadline protects your allowance.

Related: Normal Gains · Safe-Harbour · Holding Structures · Succession · Full Calculator

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