BFS NEWS • Issue 20
In this back-to-work edition, we help you tell apart what is merely an announcement from what calls for a decision: understanding the rules as they change, and anticipating before they apply to you.
The main feature of this issue focuses on tax surcharges. Since July 2025, the surcharge is waived for a first offence committed in good faith. In its judgment of 18 June 2026, the Constitutional Court extended this more favourable regime to all pending cases, regardless of when they were entered in the tax roll. The question remains who has to prove that good faith. It is presumed where a return is inaccurate, but must be demonstrated in an ex officio assessment, where far more than 10% can be at stake, including the loss of your carried-forward tax losses.
We also review the PLCI reform adopted on 16 July: ceilings rise to 8.50% (ordinary PLCI) and 9.78% (social PLCI), and the scheme opens up to those self-employed as a secondary occupation from €1,922.16 of income. For company directors, however, the 80% rule means the balance with the EIP and group insurance must be recalculated before the end of 2026.
Thinking of buying property abroad? Purpose, country, financing, estate-planning horizon: we go through the questions to ask before choosing between buying in your own name, through your Belgian company or through a foreign structure. The aim is to avoid double taxation for your heirs or an unexpected benefit in kind.
On the restructuring front, the Advance Rulings Service clarified in May 2026 the reorientation undertaking required after a demerger or contribution followed by the sale of all the shares: when it applies, how much to reinvest, how and within what time limits.
This issue also brings a flavourful encounter with Elie Salomon, founder of Whoops Agency. He was about to open a restaurant; Covid led him to put his eye for imagery at the service of Brussels restaurant owners. And, as always, your tax and administrative calendar.
