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Belgium’s New Capital Gains and Exit Tax: What Investors Need to Know Before Leaving

Belgium has changed the tax landscape for private investors.

For many years, Belgium was known for a favourable approach to capital gains on financial assets held as private wealth. That position has now changed. Belgium has introduced a capital gains tax on financial assets, applying to gains realised from 1 January 2026.

For internationally mobile investors, the most important part is not only the new capital gains tax. It is the exit-tax mechanism.

If a Belgian tax resident moves abroad, the law can treat the move as if the person sold financial assets at that moment. This can create tax exposure on unrealized gains.

For high net worth individuals, entrepreneurs, expatriates and families with investment portfolios, this changes the planning conversation completely.

This article explains the new rules, who is affected, and how DriehuisGroup can help clients structure a serious relocation plan before tax and compliance problems appear.

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1. What has Belgium introduced?

Belgium has introduced a new capital gains tax on financial assets. In general terms, the regime applies to individuals who realise gains on financial assets as part of the normal management of private wealth.

Financial assets can include:

• listed shares;
• unlisted shares;
• bonds;
• ETFs and funds;
• derivatives;
• investment insurance products;
• foreign financial assets;
• currencies and investment gold;
• crypto-assets.

Certain assets are excluded, such as pension savings accounts, group insurance and long-term savings contracts.

The standard rate for many ordinary financial assets is 10%, with an annual exemption for the first €10,000 of realised gains. The exemption applies per person and can be increased through limited carry-forward rules up to a maximum of €15,000 after five years.

The regime also contains special rules for substantial shareholdings and internal transfers.

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2. Why 31 December 2025 matters

Belgium does not intend to tax historical gains accrued before the new system.

For assets acquired before 1 January 2026, the value on 31 December 2025 is a central reference point. This date is used to determine the taxable gain on later disposals.

Example:

• You bought shares in 2020 for €500,000.
• On 31 December 2025, they were worth €800,000.
• You sell them in 2027 for €1,100,000.

The taxable gain is generally calculated from the 31 December 2025 value, not from the 2020 purchase price. In this simplified example, the post-2025 taxable gain is €300,000.

For high net worth individuals, the quality of valuation evidence is now extremely important. Listed assets may be easier to value. Unlisted companies, private holdings, family businesses, funds and complex investment products require more careful documentation.

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3. The exit-tax issue

The exit-tax mechanism is designed to prevent taxpayers from avoiding the Belgian capital gains tax by leaving Belgium before selling their assets.

When a taxpayer moves abroad, the law can deem the taxpayer to have sold investments at that moment. In principle, that means unrealized gains can become relevant for Belgian tax purposes.

This is the key risk:

You may leave Belgium without selling anything, but Belgium may still preserve a tax claim if you sell within a certain period after departure.

For relocation to an EEA country or a treaty country with exchange-of-information and recovery-assistance provisions, payment deferral may apply automatically. If the taxpayer does not realise the gain within 24 months after leaving Belgium, no exit tax should be due under the relief mechanism.

If the taxpayer sells within 24 months after emigration, Belgium may in principle levy the exit tax. Treaty analysis remains important.

For moves to certain third countries or non-treaty countries, deferral may require a request and sufficient guarantee.

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4. Who should be concerned?

The Belgian rules are especially relevant for:

• Belgian residents with significant securities portfolios;
• Belgian residents holding crypto-assets;
• entrepreneurs holding shares in private companies;
• people with substantial shareholdings;
• internationally mobile executives and expatriates;
• family offices and families with investment portfolios;
• Belgian residents planning to move abroad in 2026 or 2027;
• people who recently left Belgium and may sell assets within 24 months;
• individuals with foreign brokers or foreign accounts;
• shareholders considering gifts, transfers or restructuring involving non-residents.

The issue is not limited to billionaires. A person with a meaningful investment portfolio and a planned relocation can be affected.

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5. Example: Belgian investor moving to another EU country

A Belgian tax resident owns a portfolio of listed shares.

• Value on 31 December 2025: €2,000,000
• Value on emigration date in 2026: €2,400,000
• No assets are sold before the move
• The person relocates to another EEA country
• The person sells the portfolio 12 months after leaving Belgium

The move may trigger an exit-tax analysis because Belgium can treat the move as a deemed sale. Payment may be deferred, but a sale within 24 months can bring the Belgian tax claim back into focus.

The investor must review:

• whether Belgium can tax under domestic law;
• whether a treaty limits Belgium’s taxing rights;
• whether deferral conditions were met;
• whether annual certification obligations apply;
• whether the destination country also taxes the sale.

Without planning, the person may create a double-reporting and cash-flow problem.

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6. Example: investor leaves and does not sell

A Belgian resident moves to Bulgaria with a portfolio of listed securities.

• The person becomes properly tax resident outside Belgium.
• No portfolio assets are sold during the 24 months after departure.
• The conditions for deferral and reporting are respected.

In this simplified case, the exit tax may not become payable if no capital gains are realised during the 24-month period after leaving Belgium.

The practical point is that this result depends on execution. The taxpayer must be able to show what happened, when tax residence changed, where the person actually lives, and whether the deferral conditions have been respected.

A relocation that exists only on paper is dangerous.

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7. Example: entrepreneur with company shares

An entrepreneur owns shares in a private company and plans to move abroad before a sale.

The key questions are different from those of a simple listed portfolio:

• Is there a substantial shareholding?
• Is the planned sale already negotiated?
• Is there an internal transfer?
• Are the buyer and seller connected?
• Is the buyer inside or outside the EEA?
• What is the value on 31 December 2025?
• What is the value at emigration?
• Will Belgium claim taxing rights after departure?
• What does the destination country tax?
• Is a corporate or holding structure needed before relocation?

For entrepreneurs, timing is often the central issue. Moving after a sale has been negotiated may produce a very different result from moving before a sale process starts.

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8. What about Belgian residents who stay in Belgium?

Belgian residents who do not move still need to prepare.

The new system creates annual compliance and record-keeping requirements. Investors need to understand:

• which financial assets are in scope;
• which gains are exempt;
• whether withholding will apply;
• whether they should opt in or opt out;
• how foreign brokers will report;
• how to document 31 December 2025 values;
• how to track losses;
• how to report gains in the tax return.

For people with only a Belgian bank and simple holdings, the process may be manageable. For international investors with several brokers, foreign portfolios, crypto, private equity, company shares or unlisted assets, it can become complex quickly.

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9. What about people who already left Belgium?

Former Belgian residents should review their timeline carefully.

Important questions include:

• On what date did Belgian tax residence end?
• Was the move properly documented?
• Were Belgian registration and practical ties updated?
• Were assets sold after departure?
• Was any sale within 24 months of leaving Belgium?
• Did the destination country tax the gain?
• Is there a double tax treaty?
• Are there Belgian filing obligations remaining?

Leaving Belgium does not automatically mean that Belgian tax questions disappear. The exit-tax rule makes post-departure transactions important.

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10. What should investors do now?

A serious review should include the following steps.

Step 1: Build a full asset inventory

List all financial assets, including:

• Belgian brokers;
• foreign brokers;
• bank accounts;
• listed securities;
• funds and ETFs;
• bonds;
• crypto;
• investment insurance;
• private company shares;
• shareholder loans;
• derivatives;
• family investment structures.

Step 2: Establish 31 December 2025 values

This is critical. The valuation file should be complete, consistent and defensible.

For listed assets, closing prices may be available. For unlisted assets, more work may be required.

Step 3: Model relocation scenarios

Before leaving Belgium, compare scenarios:

• leave and sell within 24 months;
• leave and hold beyond 24 months;
• sell before leaving;
• restructure before leaving;
• move to an EEA country;
• move to a treaty country;
• move to a third country;
• move with or without family;
• move with or without operational business substance.

Step 4: Review the destination country

The destination country matters. A relocation must be tax, legal and practical.

Questions include:

• How does the new country tax capital gains?
• When does tax residence begin?
• Is there a treaty with Belgium?
• Is there local substance?
• Can the person obtain residence legally and efficiently?
• Is there a business or company setup requirement?
• What banking, accounting and reporting systems are needed?

Step 5: Execute properly

A relocation plan is only useful if implemented correctly. Paper planning without real execution creates risk.

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11. Why Bulgaria may be relevant

Bulgaria can be a practical EU base for entrepreneurs, investors and internationally mobile families who need a serious relocation solution within the European Union.

For the right client, Bulgaria may offer:

• EU jurisdiction;
• practical residency and relocation pathways;
• company setup options;
• lower operating costs;
• access to European markets;
• local accounting and legal infrastructure;
• a base for business activity and investment structuring;
• a realistic location for families and entrepreneurs who need more than a mailbox.

The important point is that relocation must be genuine. Tax residence is based on facts, not wishes.

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12. How DriehuisGroup helps

DriehuisGroup supports investors, entrepreneurs and companies entering Bulgaria and the European market with structure, discretion and local execution.

For Belgian residents and former residents affected by the new capital gains and exit-tax rules, we can coordinate:

• relocation planning to Bulgaria;
• EU residence and practical relocation support;
• Bulgarian company setup and structuring;
• coordination with Belgian tax advisors and local professionals;
• review of portfolio and company-share exposure;
• 31 December 2025 valuation file preparation coordination;
• banking and accounting setup;
• operational substance planning;
• family relocation logistics;
• implementation support before and after departure.

We focus on execution. The objective is not only to understand the rule. The objective is to create a workable plan.

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13. The key message

Belgium’s new capital gains tax changes the position of private investors. The exit-tax mechanism changes the position of people who want to leave.

If you are planning to relocate, sell a portfolio, sell a company, transfer assets, or restructure family wealth, the sequence matters.

A move should be reviewed before it happens. A sale should be reviewed before it is signed. A valuation file should be prepared before the evidence is difficult to reconstruct.

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Private case review

If you are a Belgian resident, former Belgian resident, or internationally mobile investor with assets exposed to the new Belgian capital gains and exit-tax rules, DriehuisGroup can help you assess the relocation and structuring options.

Typical first review topics:

• Current Belgian tax residence position
• Planned relocation date
• Destination country
• Portfolio size and asset classes
• 31 December 2025 valuation evidence
• Sale plans within 24 months
• Company shares or substantial shareholdings
• Family situation
• Need for Bulgarian residence, company setup or operational substance

Request a private Belgium exit-tax relocation review

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Important note

This article is general information only. It is not legal, tax or investment advice. Belgian tax outcomes depend on personal facts, residence, asset classification, valuation evidence, treaty position and future administrative guidance. Always obtain qualified tax advice before making decisions.

Need structured support in Bulgaria?

DriehuisGroup helps foreign entrepreneurs, investors, companies, and private clients coordinate practical Bulgaria routes with clearer sequencing, cleaner documents, and stronger local execution.

Contact DriehuisGroup

Disclaimer

This article is for general informational and marketing purposes only and does not replace professional advice for your specific case.