EBA quinquies: new FAQ brings practical guidance for voluntary tax regularisations
The Belgian federal tax regularisation procedure, commonly referred to as EBA quinquies, has been further clarified by a newly published FAQ. The FAQ provides practical guidance on the filing process, the supporting documents required, the applicable rates and a number of specific asset classes, including physical gold. EBA quinquies reintroduces a federal framework for taxpayers who […]
The new EU Directive 2026/799 harmonising certain aspects of insolvency law
I. Presentation and general scope of the Directive On 1 April 2026, the EU published Directive (EU) 2026/799 harmonising key aspects of insolvency law across all Member States (the “Insolvency III Directive”). The Insolvency III Directive represents a significant milestone in the gradual harmonisation of insolvency law within the European Union. It aims to improve […]
Can a critical edition of a public domain work be protected by copyright?
On 19 March 2026, the Court of Justice of the European Union (CJEU) delivered a judgment clarifying the conditions under which intellectual contributions to pre‑existing works in the public domain may qualify for copyright protection (C‑649/23, Institutul G. Călinescu). In particular, the CJEU addressed how the established EU originality standard applies where an author’s contribution […]
Belgian GAAR under closer judicial scrutiny: two recent decisions define both its reach and its limits
I. Introduction The Belgian general anti-abuse rule, set out in article 344, §1 Belgian Income Tax Code 1992 (hereafter BITC92), has long occupied a central place in tax controversy. It is also one of the most litigated areas of Belgian tax law, precisely because it sits at the intersection of two competing principles. On the […]
Environmental Claims and Sustainability Labels | What Will Change from September 2026?
In 2024, the EU Empowering Consumers for the Green Transition (“ECGT”) Directive introduced new rules that significantly tighten the regulation of environmental claims and sustainability labels, directly targeting greenwashing practices. The new rules should apply from 27 September 2026. Belgium is currently in the process of transposing the Directive. On 6 March, the Council of […]
Copyright Income and Software Development | A Renewed Opportunity for the IT Sector
I. Introduction Software developers and IT companies have long navigated a complex and shifting landscape when it comes to the Belgian tax and social security regimes for copyright income. Following the 2022 reform, computer programs were explicitly excluded from both regimes, prompting widespread uncertainty and forcing many IT-driven businesses to rethink existing remuneration and IP […]
Patent Strategy and Governance in the Defence & Security Sector | 9 Strategic Points
In the last years, the European patent landscape has changed fundamentally. A European patent (EP) no longer (necessarily) splits into a bundle of national rights; following the creation of the EP ‘with unitary effect’, and the start of the Unified Patent Court (UPC) in 2023, EP enforcement can now happen at the supranational level. This […]
The Rise of MGAs in the Insurtech Industry
What’s an MGA? An MGA is essentially an outsourced underwriting arm for insurers, but with the agility, mindset and (possibly) independence of a start-up. An MGA – or Managing General Agent – is a specific category of insurance intermediary. While nuances as to the exact role of an MGA may vary from one country or […]
New Regional Policy Declaration 2026 | The Ambitions of the New Brussels Government for Urban Planning and Real Estate
On 12 February 2026, the new Government of the Brussels-Capital Region adopted its Regional Policy Declaration (RPD). For real estate stakeholders, the message is clear: simplification of procedures, faster permitting processes, and a structural reform of the urban planning framework. Below is our analysis of the measures that will directly impact your projects. 1. An […]
Mini Series: Crypto & Tax 2026 | Explore All Episodes
Belgium’s crypto tax landscape is undergoing major transformation in 2026. This Mini Series brings together our three analyses on the evolving tax framework, from the new capital gains tax to mixedportfolio treatment and enhanced reporting obligations. Episode 1 — Capital Gains Tax & Crypto: What Shifts? Belgium’s new capital gains tax reframes crypto taxation but […]
Balancing Oversight and Privacy | The New CPC Rules on Crypto and Securities Accounts
I. Introduction Belgian tax enforcement is undergoing a structural transformation. Digitalisation, data mining and the gradual expansion of centralised reporting mechanisms are reshaping the relationship between taxpayers, financial intermediaries and the tax authorities. These trends were already visible in the recent evolution of claims enforcement, as discussed in our previous analysis on the growing role […]
One Asset Class, Multiple Strategies | Rethinking the Tax Treatment of Mixed Crypto Investments in Belgium
I. Introduction Over the past decade, crypto assets have evolved from a marginal phenomenon into a mainstream component of private wealth portfolios. Belgian resident taxpayers now frequently hold cryptocurrencies alongside traditional financial assets such as shares, bonds and investment funds. As the market has matured, so too have investment strategies. Long-term holding strategies increasingly coexist with active trading approaches aimed at capturing […]