On 29 May 2026, the Chamber of Representatives adopted the Programme Act (loi-programme) that closes a long parliamentary sequence and sets the new tax rules for the months ahead. Published in the Moniteur belge, Belgium's official gazette, on 1 June 2026, this Act directly affects Belgian SMEs and their directors through four measures that increase the tax burden on capital income.
The underlying message is clear: VVPRbis, the liquidation reserve, copyright income and securities accounts are all four affected, and the transition window was short. For SME finance directors managing their distributions, reserves and treasury — particularly those working with Odoo — the task was to revisit the distribution policy and adjust the accounting settings before 1 July 2026.
This guide sets out, mechanism by mechanism, what changes — with the precise rates, the effective dates and the concrete steps that follow from them.
1. VVPRbis: the reduced withholding rate rises from 15% to 18%
The VVPRbis regime (Verlaagde Voorheffing / Précompte Réduit bis) allows small companies within the meaning of article 1:24 of the Code of Companies and Associations (Code des sociétés et des associations, CSA) to distribute dividends at a reduced précompte mobilier — Belgium's withholding tax on movable income — subject to a waiting period.
What changes
The most favourable rate rises from 15% to 18% for dividends allocated or made payable from 1 July 2026. The regime's tiered structure is maintained:
| Financial year | Before the reform | After the reform |
|---|---|---|
| Financial year of the contribution and the following year | 30% | 30% |
| Second financial year (contributions ≤ 31 December 2025) | 20% | 20% |
| From the third financial year onwards | 15% | 18% |
Worked example
A management company distributing €30,000 in VVPRbis dividends will see its précompte mobilier rise from €4,500 (15%) to €5,400 (18%) — that is €900 of additional tax on a single distribution.
What this means for your SME
If a VVPRbis distribution is planned and the conditions are met — three-financial-year waiting period observed, cash contribution fully paid up — the applicable rate is now 18%. The trade-off is no longer about timing, which is settled, but about the amount: have your tax adviser quantify the net impact of a distribution at the new rate, compared with retaining the profits in reserve.
2. Liquidation reserve: effective taxation aligned at 18%
The liquidation reserve (réserve de liquidation / liquidatiereserve) allows SMEs to allocate their profits to a separate account, against advance payment of a separate levy of 10%. In return, the later distribution of that reserve benefited from a reduced précompte mobilier. The Programme Act aligns the effective taxation of this regime with the reformed VVPRbis.
What changes
For reserves created during financial years ending on or after 31 December 2025, the exit withholding rate rises from 6.5% to 9.8% after the three-year waiting period. Total effective taxation now reaches 18%, against approximately 15% previously.
| Date of creation | Advance levy | Exit withholding (after 3 years) | Total effective |
|---|---|---|---|
| Before 31 December 2025 | 10% | 6.5% | ~15% |
| From 31 December 2025 | 10% | 9.8% | ~18% |
Point to watch: the partial retroactivity
Reserves created during earlier financial years keep the favourable regime (6.5% after 3 years, 5% after 5 years). A transitional exception maintains the 20% rate for dividends allocated or made payable within the ten days following publication of the Act (that is, before 11 June 2026), drawn from reserves created on 31 December 2025.
What this means for your SME
Draw a clear distinction in your accounts between reserves by year of creation: those created before 31 December 2025 enjoy a lasting tax advantage. In Odoo, that distinction takes the form of dedicated sub-accounts for each financial year of creation — good practice that today takes on its full importance.
3. Copyright income: the flat-rate deduction tied to a certificate
Copyright income, up to a gross ceiling of €77,220 per year (indexed amount for 2026), constitutes movable income subject to a 15% withholding. Until now, any beneficiary could deduct a flat-rate expense allowance: 50% on the first bracket of €20,590 and 25% on the following bracket. That allowance brought the effective burden down to approximately 7.5% on the first bracket.
What changes
The Programme Act now reserves that flat-rate deduction for holders of an arts work certificate (attestation du travail des arts) of the "ordinary" or "plus" type. Beneficiaries without a certificate — or holding only a "beginner" certificate — may deduct nothing but their actual professional expenses. Failing a certificate, the 15% withholding applies to the full amount, doubling the effective burden from approximately 7.5% to 15%.
Timetable of the measure
The restriction on the flat-rate deduction applies to income since 1 January 2026. The changes concerning payment of the withholding apply only to income paid after the tenth day following publication of the Act. For rights received before that date, no correction of withholding returns already filed is required: any excess will be settled through the beneficiary's personal income tax return (impôt des personnes physiques, IPP).
What this means for your SME
If you or your director receive copyright income through the company, check your eligibility for an arts work certificate without delay with the Commission du travail des arts (CTA — werkenbijdekunsten.be). Applications can take several weeks. Failing a certificate, document your actual professional expenses carefully to minimise the tax impact.
4. Annual tax on securities accounts: a doubled rate
The annual tax on securities accounts (taxe annuelle sur les comptes-titres, TACT — jaarlijkse taks op de effectenrekeningen) applies to portfolios of financial instruments whose average value exceeds €1 million. Its rate is raised from 0.15% to 0.30%, applicable to reference periods ending on or after the date of publication of the Act, that is 1 June 2026.
Worked example
A securities portfolio with an average value of €2,000,000 will see the annual tax rise from €3,000 (0.15%) to €6,000 (0.30%) — that is €3,000 of additional cost per year.
Points to watch
The TACT targets securities accounts held by individuals and by legal entities (companies). Holding structures with substantial portfolios are therefore equally concerned. Artificial splitting of accounts intended to fall below the one-million-euro threshold remains caught by the existing anti-abuse provision.
Summary table: what changes
| Measure | Before | After | Effective date |
|---|---|---|---|
| VVPRbis — reduced withholding | 15% | 18% | Dividends allocated from 1 July 2026 |
| Liquidation reserve — exit (after 3 years) | 6.5% | 9.8% | Reserves from 31 December 2025 |
| Copyright income — flat-rate deduction | For everyone | Certificate required | Income from 1 January 2026 |
| Securities accounts tax (> €1m) | 0.15% | 0.30% | Periods ending from 1 June 2026 |
Concrete actions, now that the date has passed
The window of choice has closed: since 1 July 2026, the 18% rate applies. Here is what remains to be done, and it no longer depends on the calendar:
- Check what has already been distributed: for any VVPRbis distribution allocated or made payable before 1 July 2026, the 15% rate still applied. Verify with your tax adviser that the withholding retained does correspond to the date of allocation as determined by the Act, and not to the date of actual payment — that is where the discrepancies sit.
- Without delay: identify and segment your liquidation reserves by year of creation in your accounts. Distinguish reserves created before and from 31 December 2025: the difference in treatment justifies dedicated tracking by sub-account.
- Without delay: check the arts work certificate status for every director or employee receiving copyright income. Start the process with the CTA if necessary.
- Then: update the précompte mobilier rates in your ERP (Odoo) by type of distribution, and build the doubled cost of the TACT into your net-return projections.
How Odoo helps Belgian SMEs manage these changes
Managing distributions, reserves and withholding sits at the heart of the Odoo accounting module. The new rules of the Programme Act of 28 May 2026 translate concretely into settings to be updated.
Précompte mobilier and withholding taxes. Odoo allows withholding taxes to be configured by type of income — VVPRbis dividends, ordinary dividends, liquidation reserve, copyright income. Updating those rates ensures that every distribution automatically generates the correct entry and the correct amount to be remitted to the SPF Finances (FOD Financiën).
Tracking reserves by financial year. By creating dedicated sub-accounts for each financial year in which the liquidation reserve was created, you obtain a precise view of the rate applicable on exit — 6.5% for the earlier reserves, 9.8% for the new ones. The Odoo balance sheet then reflects the real net value of each tranche.
Simulation and reporting for the general meeting. Odoo financial reports make it possible to simulate the impact of a distribution under different scenarios of amount and financial year, to help management take decisions with full knowledge of the facts.
Need advice?
Our Odoo consultants specialising in Belgian accounting can configure your précompte mobilier rates, update your liquidation reserves and support you in reviewing your distribution policy in the light of the new rules.
Contact us for a free call →Frequently asked questions
Is the 20% VVPRbis rate for the second financial year also raised?
No. The Programme Act raises only the 15% rate (third financial year onwards) to 18%. The 20% rate applicable to the second financial year for contributions made no later than 31 December 2025 remains unchanged.
Are distributions of liquidation reserves created in 2023 or 2024 affected?
No. Only reserves created during financial years ending on or after 31 December 2025 are subject to the new 9.8% rate. Reserves created during earlier financial years keep the rate of 6.5% (after 3 years) or 5% (after 5 years).
Does my employee who receives copyright income need to obtain a certificate?
If you pay copyright income to an employee or director who benefited from the flat-rate deduction, that person must now hold an "ordinary" or "plus" arts work certificate to remain entitled to it. Without a certificate, only their actual professional expenses are deductible. Direct them to the Commission du travail des arts (werkenbijdekunsten.be).
Does the securities accounts tax also apply to companies?
Yes. The TACT targets securities accounts held by individuals and by legal entities. Holding companies and SMEs holding investment portfolios above €1 million are therefore concerned by the doubling of the rate to 0.30%.
Does Odoo handle the Belgian précompte mobilier and VVPRbis distributions?
Odoo handles withholding taxes in its accounting module. For the Belgian specifics — VVPRbis, liquidation reserve, copyright income, précompte mobilier — configuration by a certified Odoo partner is recommended to ensure that each rate is correctly set according to the new rules of the Programme Act of 28 May 2026.
Sources: Programme Act adopted by the Chamber on 29 May 2026 (Doc. parl. 56K1378); published in the Moniteur belge on 1 June 2026. SPF Finances — annual tax on securities accounts. Art. 269, § 2, CIR 92 (VVPRbis); Art. 184quater and Art. 269, § 1, CIR 92 (liquidation reserve); Art. 17, § 1, 5°, CIR 92 (copyright income). This article is provided for information purposes; have your situation confirmed by a professional adviser.