A circular dated 1 April 2026 addresses the amendments introduced by Articles 15 to 18 of the Law of 18 December 2025 to the special tax regime for inbound taxpayers (hereinafter “RSII”) and the special tax regime for inbound researchers (hereinafter “RSICI”). These amendments apply to remuneration paid or granted as from 1 January 2025.
Law until 1 January 2025
The benefits of these regimes are structured around the concept of “expenses proper to the employer.” The bearing of recurring expenses by the employer or the company, in addition to remuneration, arising directly from the assignment or employment in Belgium, is considered a non-taxable reimbursement of employer expenses, up to a maximum of 30% of the annual gross remuneration of the inbound taxpayer or inbound researcher, with an absolute cap of EUR 90,000 per calendar year. Certain other specific expenses covered by the RSII and RSICI are also treated as non-taxable reimbursements.
In addition, both regimes are subject to several eligibility conditions. Under the RSII, a minimum remuneration threshold of EUR 75,000 per calendar year applies. No such threshold applies under the RSICI.
From 1 January 2025
To enhance the attractiveness of the regime and facilitate relocation to the Belgian labour market, the Law of 18 December 2025 introduces the following changes:
- increases the maximum percentage of recurring employer expenses from 30% to 35%;
- abolishes the EUR 90,000 cap;
- reduces the RSII minimum gross remuneration threshold from EUR 75,000 to EUR 70,000.
In addition, the law provides for the possibility of retroactive application of the RSII for inbound taxpayers who started working in Belgium between 1 January 2025 and 9 January 2026 and who met all RSII conditions except the former remuneration threshold, but who now meet the new threshold of EUR 70,000.
Comments
As clarified in the circular, these changes apply retroactively as from 1 January 2025 and may, subject to conditions, be implemented in existing employment contracts. Care should be taken with regard to the impact on other remuneration-related elements.
The circular also introduces a specific transitional measure for employees who started between 1 January 2025 and 9 January 2026. Those who did not meet the former EUR 75,000 threshold may now benefit retroactively from the regime if they meet the EUR 70,000 threshold, provided that an application is submitted by 9 April 2026.
In summary, the reform makes the regime more attractive and accessible, while requiring careful practical implementation.
Moore Global Mobility
Our experts can assist you in benefiting from these new provisions. In particular, we can support you with:
- adjusting remuneration packages to align with the updated rules and ensure the 35% benefit is correctly applied through payroll;
- updating employment contracts and HR documentation to reflect the revised parameters;
- identifying employees who started on or after 1 January 2025 and who meet all conditions except the former remuneration threshold, and whose gross remuneration falls between EUR 70,000 and EUR 75,000.
