Belgium Leaving and Expat Exit Guide

Exit Tax on Substantial Shareholdings (≥25%)

• The trigger: When an individual moves their tax residence out of Belgium, a deemed capital gain is triggered on any substantial shareholding (aanmerkelijk belang / participation importante) in a Belgian company. A substantial shareholding is defined as: the individual (alone or with their spouse/partner and minor children) holds ≥25% of the shares or voting rights in a company (Belgian or foreign). The gain is calculated as the difference between the fair market value at the date of emigration and the tax cost basis.
• Tax rate: The deemed gain is taxed at 16.5% plus municipal surcharge (effective rate approximately 17.5%). This is the "meerwaardebelasting" / "impôt sur les plus-values" for substantial shareholdings. The tax is due at the time of emigration — it is NOT a deferral by default.
• 10-year deferral: The taxpayer can request a 10-year deferral of the exit tax. Under the deferral: (a) the gain is recorded in a suspense account (the "uitgestelde belasting" / "impôt différé"), (b) the suspended gain is carried forward for up to 10 years, (c) if the shares are actually sold within 10 years, the exit tax becomes due immediately, (d) if the shares are not sold within 10 years, the exit tax is waived, (e) if the taxpayer dies within 10 years, the exit tax becomes due on the estate (the "navordering" / "recouvrement" from the estate). The deferral must be applied for at the time of emigration — it is not automatic. The taxpayer must file an annual return (a "nihil" return) for the 10-year period confirming that the shares have not been sold.

Emigration Procedure

• Municipal deregistration: Before leaving Belgium, the individual must deregister from the BRP (Basisregisters van Personen / Registre de la population) at their municipality. The deregistration must be done in person or by a representative. Proof of the new foreign address is required. The municipality issues a "model 8" / "formulier 8" (the "model 8" declaration — confirming the departure and the change of address). The model 8 is sent to the FOD Financiën automatically, but the taxpayer should also inform the tax authorities directly.
• Tax return for the departure year: The taxpayer must file a partial-year tax return for the year of departure — reporting income from 1 January to the date of departure. The return must be filed as a "niet-inwoner" / "non-résident" (non-resident) for the period after departure. The tax assessment will be based on the partial year.
• Withholding tax on departure: If the individual has a Belgian employer, the employer must continue to withhold bedrijfsvoorheffing (payroll tax) for the period the individual worked in Belgium. After departure, if the individual continues to work for the Belgian employer (as a cross-border worker or remote worker), the employer must adjust the withholding based on the new tax treaty status.

Pension Portability

• IPT/VAPZ/Group insurance — early transfer: If the individual transfers the capital of a Belgian supplementary pension (IPT, VAPZ, POZ, groepsverzekering) to a foreign pension institution (a "transfer" / "overdracht" abroad), the transfer is subject to a 33% tax (plus municipal surcharge — effective ~35%). This is a punitive rate designed to discourage early transfers. The tax is due at the time of transfer.
• Keeping the pension in Belgium: The individual can keep the IPT/VAPZ capital in the Belgian insurance contract and receive it at retirement. At retirement (after age 60), the capital is taxed at the favourable rate of 10% (or 16.5% if taken earlier). The pension can be paid to a foreign bank account. The Belgian insurance company withholds the final tax at source.
• State pension portability: The Belgian state pension (wettelijk pensioen / pension légale) is portable — it can be paid to a foreign bank account anywhere in the world (the "exporteerbaar" / "exportable" pension). The pension is subject to Belgian personal income tax (progressive rates 25–50%) regardless of where the recipient lives. The Belgian tax treaty network provides for exemption or reduced rates in certain countries for state pensions.

Inheritance Tax After Leaving (5-Year Rule)

• The 5-year rule (Successierechten / Droits de succession): If an individual dies within 5 years of leaving Belgium, the Belgian tax authorities may still apply Belgian inheritance tax on Belgian-situated assets (real estate, Belgian bank accounts, Belgian company shares). The rule applies to: (a) Belgian real estate (always subject to Belgian inheritance tax regardless of the deceased's residence), (b) Belgian company shares (if the deceased owned ≥25% and was resident in Belgium within 5 years of death), (c) Belgian bank accounts if the deceased was resident in Belgium within 5 years of death (for movables — the law of the deceased's residence at death applies, but Belgium may claim tax if the deceased was resident in Belgium within the 5-year period). The "staatsbladtaks" / "taxe de sortie" applies the Belgian inheritance tax rates (3–80%) based on the relationship to the deceased.

Corporate Migration (Exit Tax for Companies)

• Corporate exit tax: When a Belgian company moves its registered office or effective management out of Belgium, a corporate exit tax applies to: (a) deemed realisation of all assets and liabilities at fair market value (the "vereffening" / "liquidation" principle), (b) deemed dissolution of the company's tax reserves. The exit tax is 25% on the deemed capital gain. Deferral is not available for corporate emigration — the tax is due immediately. The company must file a final corporate tax return (the "aangifte van vereffening" / "déclaration de liquidation") within 30 days of the decision to emigrate.

For related reading, see our Cross-Border Tax Guide →, Personal Tax Guide →, and Inheritance and Gift Tax Guide →.