Holding company in Belgium: DBI guide 2026
100% DBI dividend exemption: conditions, the 2026 reform (financial fixed assets, 5% DBI-BEVEK tax), capital gains and a worked structure example.
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Q: How does the Belgian holding company work under the DBI regime?
A Belgian holding can deduct 100% of the dividends received from its subsidiaries (DBI regime) and exempt its capital gains on shares, subject to three conditions: a participation of 10% or with an acquisition value of €2.5 million, a one-year holding period in full ownership, and a normally taxed subsidiary. Since tax year 2026, the '€2.5 million' route additionally requires the participation to be recorded as a financial fixed asset.
What is the DBI regime?
The Definitively Taxed Income (DBI, RDT in French) regime is the core of Belgium's attractiveness for group structures. Its principle: a subsidiary's profits have already been taxed at its level; when they flow up to the parent as dividends, they should not be taxed a second time. The Belgian company receiving the dividend therefore deducts 100% of it from its taxable base.
Combined with the exemption of capital gains on shares and a network of more than 95 tax treaties, the regime makes Belgium a competitive holding jurisdiction — comparable to the Dutch or Luxembourg regimes, with rules of its own.
What conditions apply to the dividend exemption?
Three cumulative conditions open the right to the DBI deduction:
- Participation condition: hold at least 10% of the subsidiary's capital OR a participation with an acquisition value of at least €2.5 million. Since tax year 2026, this second route requires the participation to be recorded as a financial fixed asset (see the reform below).
- Permanence condition: holding in full ownership for at least 1 year (or a commitment to do so).
- Taxation condition: the subsidiary must be subject to normal corporate income tax — subsidiaries established under notably more favourable regimes are excluded.
| Comparison | "10%" route Recommended | "€2.5 million" route |
|---|---|---|
| Threshold | ≥ 10% of the subsidiary's capital | Acquisition value ≥ €2.5M (even < 10%) |
| Since TY 2026 | Unchanged | Participation must be booked as a financial fixed asset |
| Typical profile | Groups, family holdings, SMEs | Minority investors in large structures |
| Holding period | 1 year in full ownership | 1 year in full ownership |
| Subsidiary taxation condition | Yes | Yes |
The 2026 DBI reform: what changes in practice
Section reviewed on 25 July 2026.
Three measures that entered into force in 2026 change the picture for Belgian holdings and their shareholders:
- Financial-fixed-asset condition (TY 2026): access to the DBI regime through the €2.5 million acquisition-value route is now reserved for participations recorded as financial fixed assets. Securities booked as treasury investments no longer qualify through this route — an immediate accounting point of attention for large minority participations.
- 5% tax on DBI-BEVEK funds (1 January 2026): DBI SICAVs, often used for corporate treasury management, are now subject to a 5% tax. The net return of these vehicles needs to be reassessed.
- 10% tax on individuals' capital gains (1 January 2026): capital gains realised by individuals on their financial assets — including shares of a holding company — are now subject to a 10% tax. This directly affects exit planning (sale of the holding by its shareholder).
These measures add to the existing framework without overturning it: the 100% exemption of dividends and capital gains at company level remains, but the accounting treatment of participations and the shareholder's personal taxation call for a review. Sources: FPS Finance and the texts published in the Belgian Official Gazette.
Are capital gains on shares exempt?
Yes — capital gains realised by a Belgian company on participations are fully exempt where the same DBI conditions are met (participation, permanence, taxation). This is what makes Belgium attractive for M&A and investment structures: the holding can sell a subsidiary without tax friction at company level.
The nuance introduced in 2026 sits at the level of the individual shareholder: the 10% tax on capital gains on financial assets applies when the individual sells his or her shares. Where the gain is located — company or shareholder — thus becomes a central parameter of any structuring.
How to structure a Belgian holding: a worked example
A simplified illustration of how the regime works, with the DBI conditions met:
- A Belgian operating company makes a profit and distributes a €100,000 dividend to its holding company (100% participation, held for more than one year).
- The holding includes the dividend in its result, then applies the €100,000 DBI deduction: the dividend bears no additional corporate tax at its level.
- No withholding tax is due between related Belgian companies in this parent-subsidiary configuration.
- If the holding later sells its participation at a gain, that gain is exempt under the same conditions.
This mechanism makes it possible to centralise the results of several subsidiaries, reinvest without tax friction and prepare a transfer. However, once funds leave the corporate sphere towards the individual shareholder (final dividend or sale), personal taxation applies: 30% withholding tax (reduced to 15% under VVPR-bis conditions for SMEs) and, since 2026, the 10% tax on individuals' capital gains.
A point of method: a holding structure is sized over the whole cycle — entry, distributions, exit — not on the DBI advantage alone. The example above is a teaching illustration, not advice: have your situation modelled by a tax lawyer.
Which legal form for the holding?
The SRL is the most common form: no statutory minimum capital (but "sufficient" equity within the meaning of art. 5:3 of the companies code), flexible articles, light governance. The SA (€61,500 capital, fully paid up, art. 7:11) remains indicated for large structures or those built to welcome investors. The DBI regime applies identically to both forms.
The formation steps are detailed in our guide Setting up an SRL in Belgium; for the full tax environment (corporate tax rates, VAT, regional duties), see Corporate taxation in Belgium.
Withholding taxes and tax treaties
- Standard withholding tax: 30% on distributed dividends.
- EU parent-subsidiary directive: full withholding exemption on dividends paid to an EU parent (participation ≥ 10%, one-year holding).
- Tax treaties: more than 95 treaties reducing withholding on dividends, interest and royalties (typically 5 to 15%).
- VVPR-bis: withholding reduced to 15% for SMEs, under conditions.
For a lawyer's support on your structure, see our page Holding company in Belgium.
Official sources
References: FPS Finance (corporate tax, withholding tax), Belgian Official Gazette / Justel (legal texts) and Fednot (incorporation). Information verified as at the date at the top of the page; legislation changes — confirm with a professional before any decision.
Frequently Asked Questions
The DBI regime (Definitively Taxed Income, RDT in French) allows a Belgian company to deduct 100% of dividends received from its subsidiaries, subject to three conditions: a participation of at least 10% of the capital OR with an acquisition value of at least €2.5 million, a holding period of at least 1 year in full ownership, and a subsidiary subject to normal corporate tax.
From tax year 2026, access to the DBI regime through the €2.5 million acquisition-value route is reserved for participations recorded as financial fixed assets. In addition, since 1 January 2026, a 5% tax applies to DBI-BEVEK funds (DBI SICAVs) and a 10% tax applies to capital gains realised by individuals on their financial assets.
Yes, capital gains realised by a Belgian company on participations are exempt if the DBI conditions are met (10% participation or €2.5M, one-year holding, normally taxed subsidiary). Beware at the level of the individual shareholder: since 1 January 2026, a 10% tax applies to capital gains realised by individuals on their financial assets.
The SRL is often preferred: no statutory minimum capital (but sufficient equity within the meaning of art. 5:3 of the companies code) and great flexibility in the articles. The SA (€61,500 capital, fully paid up, art. 7:11) suits larger structures or fundraising. Both forms enjoy the same DBI regime.
The standard withholding tax (précompte mobilier) is 30%. Dividends paid to an EU parent company holding at least 10% for one year are exempt (parent-subsidiary directive), and tax treaties — Belgium has more than 95 — often reduce the rate (typically 5 to 15%). For SMEs, the VVPR-bis regime can reduce the withholding to 15% under conditions.
Yes. To benefit from tax treaties and withstand anti-abuse rules, the holding must demonstrate real economic substance: effective management in Belgium, local decision-making and resources matching its activity. A "letterbox" holding risks being denied the tax advantages.
Ready to take action?
This guide is an informative starting point. For legal advice tailored to your situation, we can connect you with an independent lawyer registered with a Belgian bar.