The Miscellaneous Provisions Act adopted at the end of 2025 amends a set of tax and social security rules with structural consequences for businesses, executives and advisors. The text is part of a broader movement to modernise the tax administration and consolidate the budget, while seeking to improve the legal certainty of exchanges with taxpayers.
On the tax front, the most visible reform is the adjustment of taxation and investigation deadlines. The initial system was based on a combination of variable deadlines depending on the nature of the return and whether or not fraud was involved. The new framework now groups the deadlines into three blocks:
• 3 years under the standard regime;
• 4 years for so-called ‘complex’ returns;
• 7 years in cases of fraud.
In this context, the legislator is reintroducing a requirement to provide justification: in order to benefit from the extended time limit linked to fraud, the administration will have to notify the specific evidence justifying the extension of the investigation period. This clarification aims to reduce litigation and increase predictability.
At the same time, certain relief measures historically intended to support employment are gradually being phased out. This is particularly the case for exemptions for additional SME staff and measures related to social liabilities. The stated objective is to streamline a series of schemes that were deemed to be of limited relevance or costly in terms of effectiveness. For businesses, this abolition means a review of subsidised recruitment policies and labour cost projections.
The law also introduces targeted adjustments to international taxation and the status of expatriates. For foreign employees, the rules for granting specific schemes are tightened around criteria of seniority, duration and economic ties with Belgium. For non-residents, certain methods for determining the tax base and the allocation of tax credits are being revised in order to align treatment with the internal Belgian model.
At a more operational level, these changes require companies to undertake compliance work, particularly with regard to archiving deadlines, internal control procedures and anticipation of tax audits.
Our mission in the field of corporate taxation is to help you manage a reasonable tax burden that aligns with your income and the opportunities provided by tax legislation.
