Holding Company in Belgium (DBI 100%)

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 (this second route requires, from tax year 2026, that the participation be recorded as a financial fixed asset)
• 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.

The 2026 DBI Reform: What Changes for Belgian Holdings

Section reviewed on 25 July 2026 — the measures below entered into force in 2026 and must be factored into any structuring or review of a Belgian holding.

• Financial-fixed-asset condition (tax year 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 — review the accounting treatment of large minority participations now. The "10% of capital" route is unchanged.
• 5% tax on DBI-BEVEK funds (since 1 January 2026): DBI SICAVs, commonly used for corporate treasury management, are now subject to a 5% tax. The net return of these vehicles needs reassessing.
• 10% tax on individuals' capital gains (since 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. A new parameter for the shareholder's exit planning.

The 100% exemption of dividends and capital gains at company level remains: these measures adjust the access conditions and shareholder taxation without overturning the regime. Sources: FPS Finance and the texts published in the Belgian Official Gazette. For a detailed analysis with a worked example, see our guide The holding company in Belgium (DBI).