There has been a thorough reform of investment deductions for fixed assets acquired or created from 1 January 2025. The focus of this structural reform is mainly on stimulation through taxes and cash of so-called 'green investments'. Below is an overview of the main changes in the investment deduction regime in Belgium.
There has been a thorough reform of investment deductions for fixed assets acquired or created from 1 January 2025. The focus of this structural reform is mainly on stimulation through taxes and cash of so-called 'green investments'. Below is an overview of the main changes in the investment deduction regime in Belgium.
Basic deduction for sole traders and SMEs
The old standard investment deduction has been renamed to 'basic deduction' and increased from 8% to 10% for SMEs and self-employed. For digital investments relating to invoicing, customer management, e-commerce and cyber security, this basic rate even increases to 20%. The range of digital fixed assets that qualify for the 20% deduction has been extended (e.g. investments in registered cash register systems, GDPR, and digital payment, accounting and CRM systems). Large enterprises are not entitled to the basic deduction.
Fixed assets that are based on or make use of substances that are harmful to the environment and the climate are excluded from the basic deduction (unless no economically comparable emission-free alternative is available). These excluded investments are now also included in a 'climate and environmental exclusion list' (e.g. investments in fixed assets that use fossil fuels).
Thematic investment deduction
The legislator has also introduced a new thematic investment deduction of 40% for green investments by SMEs and self-employed (30% deduction for larger enterprises). The investments that qualify are now defined in so-called 'investment lists'. These lists were published in the 'Belgisch Staatsblad' on 31 December 2024. In principle, these lists will be updated every three years.
The investments that qualify for the thematic investment deduction are classified into four themes:
1. Investments in efficient energy consumption and renewable energy
2. Investments in emission-free means of transport
3. Environmentally friendly investments
4. Supporting digital investments
In turn, these themes are subdivided into groups and categories.
Theme 1: Investments in efficient energy consumption and renewable energy ('energy investment list')
| Group 1: Reduction of energy losses | Example |
| E.g. insulation of roofs, walls, etc., and high-efficiency glazing. |
| E.g. investments in which insulation material has been used. |
| E.g. draught locks, draught curtains, and automatically closing doors or gates. |
| Group 2: Recovery of energy and energy components | |
| E.g. heat and circulation pumps. |
| E.g. generators, expansion turbines and counter-pressure turbines. |
| Group 3: Adaptation of equipment, installations and industrial processes | |
| E.g. measurement and control equipment, including air conditioning software. |
| E.g. electrification of industrial production processes. |
| Group 4: Flexibility | |
| E.g. measurement and control equipment, storage systems and converters. |
| Group 5: Renewable energy | |
| E.g. equipment for the production of chemical, mechanical, thermal or electronic energy. |
Theme 2: Investments in emission-free means of transport ('transport investment list')
| Group 1: Rail transport | Example |
| E.g. investments in conversion to a CO2-free locomotive, electric locomotive on batteries. |
| Group 2: Road transport | |
| E.g. emission-free mobile vehicles and corresponding infrastructure. |
| E.g. emission-free buses, coaches and trucks. |
| Group 3: Maritime and inland navigation | |
| Group 4: Charging infrastructure | E.g. Charging infrastructure for green hydrogen or electric charging infrastructure. |
Theme 3: Environmentally friendly investments ('environmental investment list')
| Group 1: Raw material management | Example |
| E.g. water-saving equipment, industrial cleaning equipment, disinfection systems. |
| Group 2: Climate | |
| E.g. medium and high-voltage switchgear or gas-insulated lines. |
| E.g. greening of business premises, including car parks and paved areas. |
| Group 3: Investments that promote the environment | E.g. emission-free ships. |
| E.g. investments enabling the replacement of the use of chemicals of concern. |
Theme 4: Supporting digital investments ('investment list for digital support')
This theme comprises acquisitions of digital fixed assets to support investments included in themes 1 through 3 above. The list of investments for digital support will be published later on.
Formalities and certificate
For some investments, a mandatory prior energy study or audit must be carried out. In addition, a maximum amount for the investment deduction applies in certain categories.
The thematic deduction cannot be applied by companies in difficulties or companies with an outstanding recovery order for support granted in an unlawful or incompatible manner in Belgium. Furthermore, no investment deduction can be applied when regional support has already been requested for qualifying investments. In certain cases, however, a combination of both is possible.
To make use of the thematic investment deduction, a certificate issued by the competent authority must be included in the corporate tax return for the year concerned. This certificate must be requested within three months after the close of the financial year. Compliance is assessed on the basis of the investment lists in force at the time of the request. The competent authority must issue a reasoned certificate or a reasoned refusal within six months of the request.
For investments that are part of an 'investment project' running over several financial years, the taxable person has the possibility to request a 'certificate of investment'. This certificate must be requested within three months after the last day of the financial year in which the investment project was started. The advantage of such a certificate is that certainty is obtained on the qualification of the investment at the time of the start of the project. Indeed, for projects running for more than three years, it is possible that after the three-yearly update of the investment lists, these investments are no longer on the list.
Technology deduction
The 'technology deduction' has been introduced for investments in patents and fixed assets that support research and development of environmentally friendly products and future-oriented technologies. The technology deduction is a one-time deduction of 13.5%, but it may also be applied across several financial years, at an annual rate of 20.5% of the amortisation of the qualifying investment. This means that the percentages of the technology deduction are fixed and are no longer dependent on inflation.
For this deduction as well, a specific certificate must still be requested. From now on, this certificate must obligatorily be included with the tax return, which means that, de facto, the taxable person has a strict deadline for requesting the certificate. It no longer suffices to merely keep the certificate at the disposal of the administration.
Prohibition of accumulation is extended to investment deductions
Finally, the prohibition of accumulation of the tax credit for research and development and the partial exemption from the payment of withholding tax for researchers that is already in place, is extended to the various types of investment deduction. Specifically: when the investment value of an asset for which the investment deduction is applied, includes remunerations to which a full or partial exemption from withholding tax applies, the amount of the unpaid withholding tax must be taken out of the basis for calculation of the investment deduction.
We would be delighted to help you with a thorough screening of your investments and the possibilities regarding the application of the various investment deductions.
