Belgium - Comparison of special tax regime for expatriates in Belgium, Netherlands

Belgium introduced a new special tax regime for inbound taxpayers (known as BBIB/RSII) and for researchers (BBIO/RSICI) effective 1 January 2022. Given that the Belgian legislature was inspired by the Dutch special tax regime for expatriates -- the 30% rule -- foreign companies that are considering investing in either the Netherlands or Belgium are likely to compare both expat regimes, leading to interesting opportunities when opting for Belgium.

For a comparison between the old and new Belgian tax regimes, see BDO’s previous alert, Important amendments of the special tax regime for expatriates in Belgium.

Comparison of new Belgian regime and Dutch tax regime

The following overview indicates that the Dutch 30% rule inspired Belgium’s  new expat regimes:

With the new legislation in Belgium and the expected further narrowing of the scope of the Dutch 30% rule, the new Belgian expat regime may gain importance and attract employees to settle in Belgium.

Assessing the financial impact of the benefits of the Belgian expat scheme compared to the Dutch 30% rule when recruiting or seconding foreign expats will be a useful exercise for international groups with planned offices in Belgium and the Netherlands.

For Belgium, the new regime may carry extra weight in attracting foreign higher-profile positions, including management and specialists, as well as researchers.

Melissa Claessens
BDO in Belgium