The impact of the Arizona government measures on investment products & services

This content provides an outline of the expected government measures and their potential impacts on the investment products and services landscape. Please note that these measures are subject to change, this overview is intended to give a look of what “might happen” based on what is written in the Arizona government measures.

The objectives of the tax reform

The proposed reform is built around several strategic objectives:

• Strengthening the purchasing power of working people;

• Enhancing Belgium's competitiveness and attracting new investments;

• Stimulating entrepreneurship and employment;

• Simplifying the tax system to make it more transparent and user-friendly;

• Ensuring a fairer contribution from higher-income taxpayers; and

• Strengthening the fight against tax fraud and tax evasion.

Although these objectives are broad, a number of the proposed measures directly affect investment structures and financial products.

Corporate income tax: important changes for investment structures
Reform of the Dividend Received Deduction (DBI/RDT)

One of the most significant corporate tax changes concerns the Dividend Received Deduction (DBI/RDT) regime.

Under the proposal:

• The current deduction mechanism would be transformed into an exemption through an increase in the initial tax reserves.

• The minimum participation value would increase from €2.5 million to €4 million, while the 10% participation threshold remains unchanged.

• These stricter participation requirements would apply only to large companies and not to qualifying SMEs (as defined under Article 2, §1, 4°/1 ITC92).

• The same participation conditions would also apply to the exemption of capital gains on shares under Article 192 ITC92.

These changes may require large corporate groups to reassess their holding structures and participation strategies.

Changes for DBI SICAVs

The proposal also introduces important changes for DBI SICAVs:

• A 5% tax on capital gains would be introduced.

• Companies would only be able to credit the withholding tax on distributed dividends if they grant the required minimum remuneration to the company director during the relevant taxable year.

These measures could affect the attractiveness of DBI SICAVs as a corporate investment vehicle.

Private investors: introduction of a solidarity contribution

Perhaps the most widely discussed proposal is the introduction of a new 10% solidarity contribution on capital gains.

Although the exact implementation date has not yet been announced, the current proposal suggests that:

• The tax would form part of the personal income tax system.

• Capital gains would have to be reported through the annual personal income tax return.

Which assets are covered?

The proposed solidarity contribution would apply to:

• Listed shares;

• Unlisted shares;

• Other financial instruments; and

• Cryptocurrencies.

Different rules would apply to listed shares depending on the investor's participation.

Significant interest regime

The proposal distinguishes between ordinary investors and shareholders holding a significant participation.

For most private investors:

• Capital gains up to €10,000 per year (indexed annually) would remain exempt.

• Capital gains exceeding this threshold would be taxed at 10%.

For shareholders holding a significant interest (more than 20%), a progressive taxation system is proposed:

Taxable capital gain Proposed tax rate
Up to €1 million Exempt
€1 million - €2.5 million 1.25%
€2.5 million - €5 million 2.25%
€5 million - €10 million 5%
Above €10 million 10%

Importantly, the proposal states that capital gains accrued before the entry into force of the new rules would remain exempt. However, practical guidance on valuation methods, particularly for privately held companies, has not yet been published.

Stock Exchange Tax (TOB)

The Arizona coalition also intends to modernise and simplify the Stock Exchange Tax (TOB).
The objective is to create a more level playing field across different investment vehicles while reducing unnecessary complexity.
Among the announced measures are:

• Clarification and revision of the fund-of-funds provisions;

• Targeted improvements to ensure equal treatment between investment companies and funds;

• A reduction of administrative and accounting burdens; and

• Avoiding excessive regulation for initial public offerings (IPOs).

Regarding the Tax on Securities Accounts (TOSA):

• The current 0.15% tax rate would remain unchanged.

• Additional measures are expected to strengthen the fight against tax avoidance, following recommendations from the Belgian Court of Audit.

Who will be affected?

Although the legislative process is still ongoing, the proposed measures are expected to have a broad impact across the investment ecosystem.
Corporates may need to review their holding structures and financing strategies in light of the revised DBI/RDT regime.
Private investors will need to assess how the proposed solidarity contribution affects their long-term investment planning, portfolio composition and exit strategies.
Financial institutions are likely to adapt their products, advisory services and operational processes to comply with the new rules while supporting clients through the transition.

Looking ahead

The Arizona coalition's tax reform represents one of the most significant proposed changes to Belgium's investment taxation in recent years. While many practical details still need to be clarified, the direction is clear: increased transparency, revised taxation of investment income and a reshaping of both corporate and private investment strategies.

Businesses, investors and financial institutions should closely monitor the legislative process and assess how these proposals may affect their existing structures and future investment decisions.

As the reform evolves, obtaining timely tax and legal advice will be essential to navigate the changing landscape effectively.