Belgium introduced changes to its special tax regime for inbound taxpayers (STRIT) and inbound researchers (STRIR) in an act dated 18 December 2025, which was published in the Official Gazette on 30 December. The changes are effective on 1 January 2025.
The STRIT and STRIR regimes, which came into force on 1 January 2022 to replace the tax status for foreign executives that had been in place since 1983, aim to enhance Belgium's appeal to international companies. (For prior coverage, see Belgium - Eased STRIT/STRIR Rules Would Strengthen Tax Attractiveness - BDO)
The amendments introduced include:
As previously reported, there was some uncertainty as to whether the Belgian social security authorities would align their position with the tax rules. The social security authorities have now confirmed that for now the old regulations, effective since 1 January 2022, will continue to apply. This means that the changes implemented as of 1 January 2025 apply only for tax purposes and that there will be a mismatch between the exemption for tax and social security purposes.
For example, if an employee earns a gross salary amounting to EUR 90,000 and receives 35% allowances on that amount, only the first 30% of allowances is exempt from social security and taxes. The remaining 5% is exempt only from taxation and will be subject to social security contributions, resulting in a higher cost for the employer and a more complex payroll process.
With these adjustments, the Belgian government hopes to further enhance Belgium’s appeal to highly qualified foreign employees. However, considering the mismatch between the tax and social security regulations and the additional complexity resulting from it, the amended rules may not have their intended effect. Stakeholders – including BDO in Belgium -- have raised these concerns with the Belgian authorities and have requested that the social security rules be aligned with the new tax framework. For the time being, it remains uncertain whether these concerns will be addressed. We will continue to monitor developments closely and keep you informed.
Please note that employees already benefiting from the STRIR, payroll and employment contracts/addenda should be amended to reflect the revised allowance percentages and social security treatment.
For more information on how these changes may impact your employees, please consult your regular BDO contact or the author of this article.
Charlotte Lemahieu
BDO in Belgium
The STRIT and STRIR regimes, which came into force on 1 January 2022 to replace the tax status for foreign executives that had been in place since 1983, aim to enhance Belgium's appeal to international companies. (For prior coverage, see Belgium - Eased STRIT/STRIR Rules Would Strengthen Tax Attractiveness - BDO)
The amendments introduced include:
- An increase in the maximum tax-free employer allowance to 35% (from 30%) of gross remuneration;
- The repeal of the EUR 90,000 cap, so that the 35% exemption can be applied without any limitation;
- The reduction of the minimum gross salary for incoming taxpayers (but not researchers) to EUR 70,000 EUR instead of EUR 75,0000.
As previously reported, there was some uncertainty as to whether the Belgian social security authorities would align their position with the tax rules. The social security authorities have now confirmed that for now the old regulations, effective since 1 January 2022, will continue to apply. This means that the changes implemented as of 1 January 2025 apply only for tax purposes and that there will be a mismatch between the exemption for tax and social security purposes.
For example, if an employee earns a gross salary amounting to EUR 90,000 and receives 35% allowances on that amount, only the first 30% of allowances is exempt from social security and taxes. The remaining 5% is exempt only from taxation and will be subject to social security contributions, resulting in a higher cost for the employer and a more complex payroll process.
With these adjustments, the Belgian government hopes to further enhance Belgium’s appeal to highly qualified foreign employees. However, considering the mismatch between the tax and social security regulations and the additional complexity resulting from it, the amended rules may not have their intended effect. Stakeholders – including BDO in Belgium -- have raised these concerns with the Belgian authorities and have requested that the social security rules be aligned with the new tax framework. For the time being, it remains uncertain whether these concerns will be addressed. We will continue to monitor developments closely and keep you informed.
Please note that employees already benefiting from the STRIR, payroll and employment contracts/addenda should be amended to reflect the revised allowance percentages and social security treatment.
For more information on how these changes may impact your employees, please consult your regular BDO contact or the author of this article.
Charlotte Lemahieu
BDO in Belgium