As announced in the “Easter Agreement” and now enacted in a draft law, amendments to the ‘new’ special tax regime for inbound taxpayers (STRIT) and inbound researchers (STRIR) have been proposed. This regime, which came into force on 1 January 2022 to replace the tax status of foreign executives in place since 1983, aims to enhance Belgium's appeal to international companies.
The draft law introduces further easing of the regime, strengthening Belgium’s competitiveness compared to neighbouring countries with similar regimes.
The following changes would be implemented:
The social security authorities have confirmed in the past that reimbursements under the STRIT/STRIR regime are free from social security contribution requirements. The proposed amendments (increase of the maximum percentage to 35% and abolishing of the annual maximum amount) are not expected to affect this position.
These amendments would apply to remuneration paid or granted from 1 January 2025. Therefore, the changes may also be applied (retroactively) to employees who are already benefiting from the special tax regime.
In the example below (for a single taxpayer), the net salary has been determined with a cost for the employer of EUR 135,000 in the following scenarios:
Raising the maximum percentage of the tax-free allowance to 35% affects the employee’s net income positively.
Employers are advised to reflect on how they may apply these changes to their employees and directors who already benefit from the STRIT/STRIR regime. It is also strongly recommend that employers adjust the addendum to the employment contract so that it adequately reflects the new agreement.
With these adjustments, Belgium would proactively strengthen its position in the global competition for talent and investment. By enhancing the STRIT/STRIR regime, through measures such as a higher expense allowance and a lower salary threshold, the tax framework becomes more competitive relative to neighbouring countries. This is expected to support the Belgium’s ability to attract and retain highly qualified foreign employees and researchers.
For more information on how these changes may impact your employees, please consult your regular BDO contact or the authors of this article.
Charlotte Lemahieu
Lien Maerevoet
BDO in Belgium
The draft law introduces further easing of the regime, strengthening Belgium’s competitiveness compared to neighbouring countries with similar regimes.
The following changes would be implemented:
- The maximum tax-free allowance percentage would increase from 30% to 35% of gross remuneration paid.
- The tax-free allowance would no longer be capped at EUR 90,000.
- The minimum gross salary to be eligible for the STRIT regime (i.e., gross salary before deduction of social security contributions, but including holiday pay, year-end bonuses, benefits in kind, and bonuses (unless these are uncertain at the time of application)) would be reduced from EUR 75,000 to EUR 70,000 per calendar year.
The social security authorities have confirmed in the past that reimbursements under the STRIT/STRIR regime are free from social security contribution requirements. The proposed amendments (increase of the maximum percentage to 35% and abolishing of the annual maximum amount) are not expected to affect this position.
These amendments would apply to remuneration paid or granted from 1 January 2025. Therefore, the changes may also be applied (retroactively) to employees who are already benefiting from the special tax regime.
In the example below (for a single taxpayer), the net salary has been determined with a cost for the employer of EUR 135,000 in the following scenarios:
- No application of the STRIT rules (regular resident tax calculation)
- Application of the current STRIT rules
- Application of the proposed STRIT
| Belgian resident | Belgian resident | Belgian resident | |
| Without STRIT | Application of "old" STRIT | Application of "new" STRIT as of 01/01/2025 | |
| Employer cost | 135.000,00 | 135.000,00 | 135.000,00 |
| -Social security contributions employer | -27.984,05 | - 22.607,66 | - 21.906,21 |
| Total gross “package” | 107.015,95 | 112.392,34 | 113.093,79 |
| (gross salary incl. TFA) | |||
| -Tax free allowances | 0,00 | -25.936,69 | -29.320,61 |
| Gross salary excl. TFA | 107.015,95 | 86.455,65 | 83.773,18 |
| -Social security | - 13.916,65 | - 11.242,93 | - 10.894,09 |
| contributions employee | |||
| Taxable income | 93.099,30 | 75.212,72 | 72.879,09 |
| -Income tax | - 36.706,19 | - 27.184,70 | - 25.942,44 |
| -Special social security | - 731,28 | - 731,28 | - 731,28 |
| Tax free allowances | 0,00 | 25.936,69 | 29.320,61 |
| Net income | 55.661,82 | 73.233,43 | 75.525,98 |
Raising the maximum percentage of the tax-free allowance to 35% affects the employee’s net income positively.
Employers are advised to reflect on how they may apply these changes to their employees and directors who already benefit from the STRIT/STRIR regime. It is also strongly recommend that employers adjust the addendum to the employment contract so that it adequately reflects the new agreement.
With these adjustments, Belgium would proactively strengthen its position in the global competition for talent and investment. By enhancing the STRIT/STRIR regime, through measures such as a higher expense allowance and a lower salary threshold, the tax framework becomes more competitive relative to neighbouring countries. This is expected to support the Belgium’s ability to attract and retain highly qualified foreign employees and researchers.
For more information on how these changes may impact your employees, please consult your regular BDO contact or the authors of this article.
Charlotte Lemahieu
Lien Maerevoet
BDO in Belgium