Belgium’s Programme Law 2026, published in the Moniteur Belge earlier this year, fundamentally alters the tax treatment of liquidation reserves and VVPRbis dividends, and with it, the calculus behind every company liquidation decision in Belgium. Directors, CFOs and liquidators now face higher withholding rates, shortened waiting periods and a new anti‑abuse provision that together reshape how after‑tax proceeds flow to shareholders and creditors. For companies already weighing insolvency, reorganisation or voluntary wind‑down, the insolvency tax implications are immediate: distributions made from 1 July 2026 onward will be subject to materially different rules.
This guide provides a practical, step‑by‑step…