Corporate Tax: Minimum Remuneration Increases to €50,000 for the Reduced Rate

Belgium’s tax reform is taking concrete shape for SMEs. One of the key measures is the increase in the minimum remuneration required to benefit from the reduced rate of corporate income tax.

Until now, the minimum remuneration was set at €45,000.

This amount will be increased to €50,000 (indexed).

Is this already applicable?

Not yet.

At present (assessment year 2025), the threshold remains €45,000.

The reform has been adopted as part of the 2025–2029 fiscal program, but the new rule will enter into force as from assessment year 2026.

In practice:

• Ongoing financial years → threshold = €45,000
• As from assessment year 2026 → threshold = €50,000 (indexed)

In other words, for a company closing its financial year on 31 December 2025, the €45,000 rule still applies for the taxation relating to 2025.

Why this minimum remuneration?

The reduced tax rate of 20% applies to the first €100,000 of taxable profit (instead of the standard rate of 25%).

To benefit from this reduced rate, a company must:

• Qualify as a small company within the meaning of the Belgian Code of Companies and Associations
• Grant a minimum remuneration to at least one company director
• Comply with the limitation on benefits in kind

The legislator’s objective is clear:

to prevent structures where directors grant themselves artificially low remuneration in order to maximize the portion of profit taxed at the reduced rate.

Impact for SMEs

This €5,000 increase is not insignificant.

It may require:

• An adjustment of directors’ remuneration policies
• A review of tax planning for 2025–2026
• Particular attention for companies close to the threshold

Some SMEs will need to choose between:

• Increasing the director’s remuneration
• Losing access to the reduced rate
• Or revising their distribution strategy (dividends, reserves, etc.)

What if the taxable profit is below €50,000?

If the company does not generate sufficient taxable profit to reach €50,000, the law provides for an adjustment:

The minimum remuneration may be limited to the amount of the taxable profit if this is lower than the statutory threshold.

Article 215, paragraph 3 of the Belgian Income Tax Code 1992 The reduced rate referred to in paragraph 2 applies only if the company grants to at least one of its company directors, as referred to in Article 32, §1, a taxable remuneration of at least €45,000. Where the company’s taxable profit is lower than €45,000, the remuneration must be at least equal to the taxable profit. For the purposes of this paragraph, benefits in kind referred to in Article 36 may not exceed 20% of the gross remuneration.

A matter to be assessed on a case-by-case basis.