What's the new Belgian CGT regime from 1 January 2026?

Belgium introduced a 10% CGT on financial-asset gains exceeding €10,000 annually (effective 1 January 2026), with a 33% rate on disposals of substantial holdings (>20% control where the acquirer is a related party). Only post-31-Dec-2025 accumulated gains are taxed — pre-2026 gains are protected if the cost basis at 31 Dec 2025 is documented. The valuation memo is the critical artefact.

Should I relocate to Cyprus before or after 1 January 2026?

Mostly before — locks in pre-2026 cost basis on Belgian-sited assets and avoids the new CGT regime entirely on subsequent Cyprus-resident disposals. After 1 January 2026: the regime is in effect, but Cyprus residency before any major realisation event still moves the disposal to Cyprus-source (0% CGT). Specialist Belgian + Cyprus counsel essential for the timing.

How does Belgian regional inheritance tax work?

Brutal — and regionally administered. Brussels and Wallonia: up to 80% for unrelated heirs. Flanders: cleaner. Direct line: 3-30% Flanders, 3-30% Wallonia/Brussels. Belgian-sited property remains in the regional inheritance scope regardless of Cyprus residency. Pre-relocation restructuring (e.g. Cyprus HoldCo above Belgian SCI / SC) needed to mitigate.

Can I use the new Belgian expat tax regime AND then relocate?

The Belgian expat regime (replacing the pre-2022 system): up to 30% of gross salary tax-free (capped €90,000), proposed increase to 35% uncapped, minimum salary €70,000. Inbound only; 5+3 year duration. It's a sweetener for arrivals into Belgium, not a tool for departures. For founders considering the move out of Belgium, Cyprus 17-year non-dom is the structurally-deeper offer.

How does the Belgium-Cyprus DTT work?

BE-CY DTT signed 1996. Headline rates: dividends 10/15%, interest 10%, royalties 0%. Treaty tie-breakers + EU directive supplementation. Combined with the Belgian regional-inheritance complexity, the cross-border structuring is heavier than e.g. Spain or the UK.

What about ATAD III / shell-company-directive implications?

ATAD III (Unshell Directive) is delayed but pending. Brussels is among the most aggressive at implementing anti-shell measures. Cyprus structures with real Cyprus substance (board, office, expenditure, decision-making) pass ATAD III tests; pure-conduit structures fail. Substance discipline matters more from Belgium than from most EU jurisdictions.

For Belgianfounders & HNWIs

Cyprus structures for Belgian founders — 1-Jan-2026 CGT-aware

From 25% BE CIT + 53.5% top PIT + new 10/33% CGT (Jan 2026) + regional inheritance up to 80% to Cyprus 15% / 35% / 0%. Pre-1-Jan-2026 cost-basis lock-in is the critical timing window.

~80%

BE Brussels max IH

CY CGT shares

CY inheritance

Book a free 30-min call See fixed-fee pricing

— The structural argument

Why Belgian founders pick Cyprus

Cyprus 0% inheritance vs Belgian regional up to 80%

Belgian regional inheritance can hit 80% in Brussels for unrelated heirs. Cyprus inheritance tax: 0% (abolished). For founders building generational wealth, the inheritance differential is the dominant structural argument — even before considering the new 2026 CGT regime.

Pre-2026-CGT relocation window

The new Belgian CGT regime (10% / 33%) applies only to post-31-Dec-2025 gains. Cyprus relocation before 1 Jan 2026 locks in pre-regime cost basis on Belgian-sited assets. Cyprus residency thereafter shifts disposals to 0% Cyprus CGT.

Cyprus 17-year non-dom vs Belgian expat regime

Belgian expat regime is inbound (up to 30% of salary tax-free, cap €90k, 5+3 year duration). Cyprus non-dom is the outbound: 0% SDC on dividends + interest, 17 years, no minimum-tax. For founder-equity events + dividend extraction, Cyprus is materially deeper.

EU-EU treaty + Parent-Subsidiary Directive

Both EU. Qualifying corporate-to-corporate dividends flow at 0% WHT under the EU directive (≥10% / ≥24 months). BE-CY DTT (1996) supplements with reduced WHT on individual flows.

— Day 0 → Day 90

Your Cyprus transition, end-to-end

Belgian-specific workstream from first call to operational Cyprus structure.

Day 0–7: Pre-2026-CGT timing diagnostic + Belgian counsel
Free 30-min call. We sketch the Cyprus structure, flag the 1-Jan-2026 CGT timing, identify regional inheritance + ATAD III considerations. Belgian tax counsel engaged.
Day 7–25: Cyprus company formation + Belgian valuation memo
Cyprus Ltd formation. Belgian-side: 31-Dec-2025 valuation memo for cost-basis lock-in (if relocating in 2026).
Day 25–55: Cyprus banking + Belgian residency-cut prep
Cyprus bank account opening. Belgian-side residency-cut documentation: commune deregistration, tax-residency-cut filing, Cyprus economic-centre evidence.
Day 30–70: Yellow Slip + Non-Dom + TIN
Cyprus residence permit (Yellow Slip — EU citizen). Form T.D. 38 non-dom registration. Cyprus TIN.
Day 45–100: Belgian estate + IH planning
Belgian-sited property restructuring (where applicable) for regional inheritance mitigation. Cyprus HoldCo positioning if Belgian SCI / SC in scope.
Day 60–120: Operational structure + first compliance
First Cyprus dividend (0% SDC under non-dom). Annual cycle: Cyprus IR4 + Belgian non-resident return for residual.

— Side-by-side

Compared to staying in Belgium

Dimension	Staying in Belgium	Cyprus structure
Headline corporate tax	25% standard / 20% SME first €100k	15%
Top personal income tax	~53.5% (50% federal + ~7% municipal)	35% + 50% high-earner exemption
Capital gains on shares (from 2026)	10% (>€10k/yr) / 33% (substantial holdings)	0% (only Cyprus-property)
Inheritance tax	Regional: 3-30% direct line / up to 80% unrelated (Brussels)	0%
Effective rate on qualifying IP	25% (no IP Box equivalent)	~3% via IP Box
Combined social contributions	~38% combined (employee + employer)	GHS 2.65% capped + SI on insurable up to €70,148
Wealth / solidarity tax	Variable; some regional+communal levies	0% — no wealth tax

Indicative side-by-side. Your specific position depends on income mix, holdings, and Belgium-side exit-tax mechanics. Engagement-letter analysis required.

— Treaty & legal essentials

Belgium–Cyprus regulatory map

Belgium–Cyprus DTT (1996)

Dividends 10/15%, interest 10%, royalties 0%. Treaty tie-breakers + EU directive supplementation.

Belgian 2026 CGT regime

10% on financial-asset gains > €10k/yr; 33% on substantial-holding disposals to related parties. Effective 1 Jan 2026. Pre-2026 cost basis must be documented at 31 Dec 2025 to be protected.

Belgian regional inheritance tax

Up to 80% in Brussels for unrelated heirs. Belgian-sited property remains in regional scope regardless of Cyprus residency. Pre-relocation restructuring (Cyprus HoldCo) is the standard mitigation.

ATAD III (Unshell Directive — pending)

Brussels-led anti-shell-company directive. Cyprus structures with real Cyprus substance pass; pure-conduit structures fail. Substance discipline + decision-making documentation are essential.

— What we handle end-to-end

The full Cyprus transition stack

— Fixed-fee, transparent

Tax Resident from €1,899 · Relocate & Launch from €4,899 · 60-Day Nomad from €5,899. All + VAT. No "contact us for a quote".

See full relocation pricing

— Common questions

Belgian founders ask

Reviewed by

Nexora Editorial Standards Board

ICPAC-coordinated · Cyprus Bar partner-firm

Updated May 2026

Engagements coordinated with ICPAC-registered Cyprus tax advisers and Cyprus Bar Association member-firm lawyers. MOKAS-aligned under Cyprus AML Law 188(I)/2007. See our editorial standards and disclaimer.

“Walked into the call confused, walked out with a 4-step plan, fixed-fee quote, and a Cyprus company set up two weeks later. No surprises on the bill.”

M. Kowalski

SaaS founder · Poland

Published with permission. Initials shown to preserve commercial-privacy preference.

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Dimension

Staying in Belgium

Cyprus structure

Headline corporate tax

25% standard / 20% SME first €100k

15%

Top personal income tax

~53.5% (50% federal + ~7% municipal)

35% + 50% high-earner exemption

Capital gains on shares (from 2026)

10% (>€10k/yr) / 33% (substantial holdings)

0% (only Cyprus-property)

Inheritance tax

Regional: 3-30% direct line / up to 80% unrelated (Brussels)

Effective rate on qualifying IP

25% (no IP Box equivalent)

~3% via IP Box

Combined social contributions

~38% combined (employee + employer)

GHS 2.65% capped + SI on insurable up to €70,148

Wealth / solidarity tax

Variable; some regional+communal levies

0% — no wealth tax

Cyprus structures for Belgian founders — 1-Jan-2026 CGT-aware

Why Belgian founders pick Cyprus

Cyprus 0% inheritance vs Belgian regional up to 80%

Pre-2026-CGT relocation window

Cyprus 17-year non-dom vs Belgian expat regime

EU-EU treaty + Parent-Subsidiary Directive

Your Cyprus transition, end-to-end

Compared to staying in Belgium

Belgium–Cyprus regulatory map

Belgium–Cyprus DTT (1996)

Belgian 2026 CGT regime

Belgian regional inheritance tax

ATAD III (Unshell Directive — pending)

The full Cyprus transition stack

Belgian founders ask

01Should I move now or wait for ATAD III enactment?

02How do I document my 31-Dec-2025 cost basis?

03What about my Belgian-sited real estate after I move?

04Can I keep my Belgian SA / SRL and just move personally?

05What about Belgian DBI / participation exemption interaction?

06Is the Cyprus 60-day rule available to a Belgian founder?

07What about Belgian Cassa / pensions during transition?

08Does Cyprus have a French / Dutch-speaking practitioner network?

Related Cyprus services, tools & guides.

Cyprus structures for Belgian founders — 1-Jan-2026 CGT-aware

Why Belgian founders pick Cyprus

Cyprus 0% inheritance vs Belgian regional up to 80%

Pre-2026-CGT relocation window

Cyprus 17-year non-dom vs Belgian expat regime

EU-EU treaty + Parent-Subsidiary Directive

Your Cyprus transition, end-to-end

Compared to staying in Belgium

Belgium–Cyprus regulatory map

Belgium–Cyprus DTT (1996)

Belgian 2026 CGT regime

Belgian regional inheritance tax

ATAD III (Unshell Directive — pending)

The full Cyprus transition stack

Belgian founders ask

01Should I move now or wait for ATAD III enactment?

02How do I document my 31-Dec-2025 cost basis?

03What about my Belgian-sited real estate after I move?

04Can I keep my Belgian SA / SRL and just move personally?

05What about Belgian DBI / participation exemption interaction?

06Is the Cyprus 60-day rule available to a Belgian founder?

07What about Belgian Cassa / pensions during transition?

08Does Cyprus have a French / Dutch-speaking practitioner network?

Related Cyprus services, tools & guides.