For almost forty years, around thousands of foreign executives and researchers in Belgium lived with an unusual arrangement. They had a Belgian address, a Belgian employer, and children in Belgian schools, and for tax purposes they were treated as if they lived somewhere else.
That arrangement came to an end in 2022, replaced by a new regime that got rewritten again at the end of 2025 into an even more generous version.
So why does a country with a top income tax rate of 50%, plus a municipal surcharge, hand out tax-free money to new arrivals so easily? And what does the regime look like from the inside, when the press release headlines are set aside?
In this article, you will learn:
- What the regime is and how it got to where it is now
- Who qualifies for it
- How the tax-free allowance works on salaries
- Why social security treats one part of that allowance differently
- Who cannot use the regime at all
This is a guide to how the system works, written for anyone considering moving to Belgium. Individual eligibility is always determined by the Belgian tax authorities based on the facts of a specific case.
Key takeaways
- Belgium's special tax regime for inbound taxpayers lets employers pay qualifying people recruited from abroad a tax-free allowance of up to 35% of gross salary, on top of that salary, for up to eight years.
- The regime is open only to employees and certain company directors. Self-employed professionals cannot apply, however much they earn or wherever they come from.
What the regime is
The official name is a mouthful: the special tax regime for inbound taxpayers, known in Dutch as BBIB and in French as RSII. There’s a parallel version of it for inbound researchers (BBIO in Dutch, RSICI in French).
Both of these came into force on January 1st, 2022, through the Program Law of December 27th, 2021.
In basic terms, the regime allows a Belgian employer to reimburse a qualifying person for the additional costs of living and working in a country that is not their own. Those reimbursements go as costs to the employer, so they escape income tax. High rent, trips home, the general expense of starting over somewhere new; the employer can cover all of it without the tax authorities taking a share.
The two versions differ mainly on the requirements to join:
- Inbound taxpayers need a minimum salary but no particular degree
- Inbound researchers need no minimum salary but must have a relevant master’s or doctoral degree or prove ten years of relevant experience and spend at least 80% of their working time on research and development.
Researchers must be employees. The inbound taxpayer route is also open to some company directors.
From a tax fiction to a tax allowance
Understanding the old system explains a lot about the new one.
Belgium’s previous expat status dates back decades, but it existed only as an internal instruction from the tax administration, not as an actual statute. Its most distinctive feature was a fiction of non-residence. Qualifying executives were taxed as non-residents, and pay linked to days worked outside Belgium could escape Belgian tax altogether. The result was striking for an average director who spent half of the year on planes.
Lawmakers removed that fiction in 2022. Inbound taxpayers are now subject to the normal Belgian residence rules, meaning a person whose home and economic interests are in Belgium is taxed there as a resident on worldwide income. The new regime offered instead the allowance described below, written into statute rather than relying on an administrative practice that could be changed at any time.
That is an important change because Belgian personal income tax goes from 25% to 50%, and municipalities add a surcharge of up to 9% of the due tax.
So, who qualifies?
Eligibility depends on a set of conditions. Missing just one condition rules the regime out, however well the others fit.
- Recruitment from abroad. The person must be hired directly from outside Belgium, or seconded to a Belgian entity from a foreign company in the same multinational group.
- A qualifying employer. This means a Belgian company, the Belgian establishment, or a non-profit organization.
- No recent ties to Belgium. For the 60 months before starting work, the person must not have been a Belgian tax resident, must not have paid Belgian non-resident tax on professional income, and must not have lived within 150 kilometers of the Belgian border.
- A salary above €70,000. This applies to inbound taxpayers only. The figure is annual gross pay taxable in Belgium, pro-rated for part years. The allowance itself cannot be used to reach it.
The most surprising part is the 150-kilometer rule. Someone living in Lille, Maastricht, Aachen, or Luxembourg City for the past five years is ruled out, even though they live in a different country from Belgium.
The €70,000 limit is also recent. Until the law of December 18th, 2025, it stood at €75,000, but the change applies retroactively from January 1st, 2025.
How the 35% allowance works
So, what does 35% look like on an actual payslip?
Under the regime, an employer can pay a tax-free allowance of up to 35% of gross salary, on top of that salary. The previous maximum was 30%, with an annual limit of €90,000. The December 2025 law we’ve mentioned raised the percentage and eliminated the euro limit, again with effect from January 1st, 2025.
As an example, let’s take an employee on a gross salary of €100,000. The employer can add up to €35,000 of tax-free allowance, for a total package of €135,000. Of that package, around 25% is tax-free, which is a little different from “35%” suggested at first glance. The allowance is calculated on the salary, and the salary is only part of what the employee receives.
Some one-off costs can be reimbursed tax-free in addition to the allowance. These can be moving costs, setting-up costs during the first six months, and school fees. They come on top of the percentage.
However, there’s one practical point both employers and employees should be aware of. The allowance has to be agreed and paid as a genuine reimbursement of the costs. Deloitte notes that recent tax audits have read contract wording narrowly, so how the allowance is written into the employment agreement deserves as much care as the amount.
The social security exception
As we’ve covered, the tax rules changed in December 2025. The social security rules, however, did not. The National Social Security Office confirmed in its instruction 2025/4 that the exemption from the social contributions still follows the version of the rules in force on January 1st, 2022: a maximum of 30%, limited to €90,000 a year.
In practice, the allowance now splits into two parts. Back to the €100,000 salary:
- The first €30,000 is exempt from both income tax and social security contributions
- The remaining €5,000 is exempt from income tax but subject to employee and employer social security contributions.
For very high earners, the €90,000 social security limit adds another layer. This EY analysis explains a €300,000 salary, where everything above the first €90,000 of allowance becomes subject to contributions while staying free of income tax.
Employer groups have asked the authorities to align the two systems. Until that happens, payslips will follow both sets of rules at once.
Applying, and how long it lasts
The regime does not apply automatically. The employer files an electronic application with the tax authorities within three months of the employee starting work in Belgium, together with the employee’s signed agreement. The authorities then have another three months to decide.
As soon as it's granted, the regime lasts for five years, with an option of a three-year extension which requires a new application within yet again three months of the first period ending. Changing employers doesn’t reset that timeframe. Employees need a new application, but the period is still counted from the date of the person’s first employment in Belgium, so the eight-year maximum remains the same.
Each year, the employer also reports the names of everyone who benefited from the regime in the previous year.
Who cannot use the regime?
There’s one group that never appears in the conditions above: the self-employed.
The regime only works for employers who recruit from abroad, file the application, and pay the allowance. An independent consultant who moves to Brussels and invoices clients directly has no such employer, so there’s no route into the regime for them. Self-employed people in Belgium have a different system of income tax and social contributions altogether, which you can read about in our article about self-employed social security in Belgium.
That makes employment status the first factor that access depends on, well before salary, nationality or the 150-kilometer rule.
How Hightekers can help
If you’re a freelancer looking to move to Belgium, the question of status comes before everything else, and it defines much more than a tax: social security coverage, pension accrual, and how a bank or a landlord sees your income status.
Hightekers employs freelancers in Belgium under a genuine employment contract. You keep your own clients and set your own rates, while Hightekers signs the service agreement with your client, handles invoicing, payroll, and compliance, and provides the employee benefits that come with such a contract.
Visit the Belgium country page to see how the arrangement works there, and request a personalized simulation on your day rate.
FAQ
What is the Belgian expat tax regime?
It is the special tax regime for inbound taxpayers and inbound researchers, in force since January 1, 2022. It allows a Belgian employer to pay qualifying people recruited from abroad a tax-free allowance of up to 35% of gross salary, in addition to that salary.
What is the minimum salary for the regime?
More than €70,000 in annual gross pay taxable in Belgium, following a December 18, 2025 law that retroactively lowered it from €75,000 to €70,000, effective January 1, 2025. Researchers have no salary requirement, but must meet degree or experience conditions.
How long does the regime last?
Five years, with a possible three-year extension, for a maximum of eight. Changing employer requires a new application but does not restart the period.
Can self-employed professionals use the regime?
No. The regime applies only to employees and certain company directors recruited from abroad or seconded within an international group. Self-employed people are taxed under the standard rules.
Are expats under the regime taxed as Belgian residents?
Yes, where they meet the normal residence criteria. The current regime no longer treats beneficiaries as non-residents, so residents are taxed in Belgium on their worldwide taxable income, with the allowance itself exempt.
