Belgium Holding Company 2025 | DBI 100% Exemption, Capital Gains
Form your holding company in Belgium. 100% DBI exemption on dividends, exempt capital gains, notional interest deduction. Optimal tax structure at the heart of Europe.
In summary: Belgium offers one of Europe's most competitive holding regimes with the DBI system allowing 100% exemption on dividends from subsidiaries. Capital gains on participations are fully exempt under the same conditions, making Belgium attractive for group structures and M&A operations.
The Belgian Holding Regime
Belgium offers one of Europe's most competitive holding regimes. The DBI system allows near-total exemption of participation income, making Belgium a jurisdiction of choice for group structures.
DBI Regime: Dividend Exemption
The DBI regime allows 100% deduction of dividends received from subsidiaries. Conditions:
- Participation threshold: 10% of capital OR acquisition value ≥ €2.5 million
- Holding period: Minimum 1 year (full ownership)
- Taxation condition: Subsidiary must be subject to normal corporate tax
Exempt Capital Gains
Capital gains on participations are fully exempt if the same DBI conditions are met. This makes Belgium attractive for M&A operations.
Tax Treaty Network
Belgium has concluded over 95 tax treaties, enabling reduced withholding taxes on incoming dividends, interest, and royalties.
Frequently Asked Questions
The DBI (Definitively Taxed Income) regime allows 100% deduction of dividends received from subsidiaries. Conditions: participation of at least 10% or acquisition value of €2.5 million, minimum 1-year holding period, and the subsidiary must be subject to normal corporate tax.
Capital gains on shares realized by a Belgian company are exempt if DBI conditions are met (10% participation or €2.5M, 1-year holding). For individuals, capital gains are generally exempt unless speculative.
The notional interest deduction allows deducting a fictitious interest calculated on adjusted equity. The rate varies annually (around 0.5% for large companies, plus 0.5% for SMEs). This reduces the tax advantage of debt financing.
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