What changes in the taxation of your fund and ETF?

The reforms of the De Wever government will not leave your investment funds and ETFs indifferent either. With the arrival of the capital gains tax and a different regulation for the DBI funds, there is once again extra cash in the fund landscape. What will change in concrete terms?

The taxation of funds and ETFs is a perfect example of the complexity with which our country burdens its taxpayers. The different and inexplicable uses of the stock market tax for ETFs, the tax differences between securities and mutual funds, and the ruined Reynders tax: these are just a few examples that illustrate how complicated taxation is for fund investors.

In the search for new income, the De Wever government is launching a few new taxes that add an extra layer of complexity.

1/ Capital gains tax

As of 1 January 2026, the capital gains tax will take effect. If all goes well, because the banks have already indicated several times that they may not finish implementing by the end of this year. We are also still waiting for the final legal texts, so that last minute adjustments cannot be ruled out. But the major modalities are fixed.

Anyone who sells their fund or ETFs from next year will now pay a 10 percent capital gain tax. The added value is calculated by reducing the sales price by the purchase price. If the fund was purchased earlier, the purchase price will be taken at the rate of 31 December 2025.

But if the effective purchase price is higher in that case and you can prove that, you can take that effective purchase rate. This way, you avoid paying capital gains tax on a capital gain that you have not realized. This return to the effective purchase rate before December 31, 2025 is possible until December 31, 2030, and from then on, the rate from the end of 2025 will always apply to old purchases.

It is important that you receive an annual exemption. Capital gains of up to 10,000 euros - across all your investments - are exempt from tax annually. If you do not use the exemption one year, 1,000 euros will be added the next year. This will continue for a maximum of five years and the ceiling of 15,000 euros of exemption in one year.

Those who want the exemption will have to apply for it themselves via their tax return. Even if you want to make use of the higher purchase price before December 31, 2025, you will have to request it yourself via the declaration.

This also applies to the minus values that you charge. If you sold securities at a loss in that year, you can deduct that minus value from the taxable capital gain. This must also be done via the declaration.

Those who bought their fund or ETF through a Belgian bank or intermediary can choose. Or the bank deducts the capital gain tax immediately upon sale. This is also the case, for example, with withholding tax on dividends. The other option is to opt out. In that case, the bank will not deduct the capital gains tax and you must declare them in your tax return. Anyone who sells their fund to a foreign bank or broker may have to declare the capital gains tax themselves anyway, because foreign players do not deduct Belgian taxes. This is important for ETF investors who are customers of foreign brokers.

2/ Reynderstaks

Of the 300 billion euros that Belgians hold in funds and ETFs, around 178 billion are in funds that invest at least 10 percent in fixed income securities and are therefore subject to the Reynderstaks.

This mainly concerns bond funds or mixed (stocks and bonds) funds.

The 30 percent Reynders Tax has been around since 2006 and is applied to the added value that investors achieve when selling through the fixed income part of their fund. For example, if you sell a mixed fund that invests in both stocks and bonds, only the capital gain that the fund made through the bonds will be taxed. Unless there is a minus value on the share portion, that minus value will be deducted first. If the investor sells his fund at a loss, but there is capital gain from the bond section, no Reyndertax applies.

To prevent the introduced capital gains tax from leading to double taxation for fund investors, the new tax will only tax capital gains that are not subject to the Reynders tax.

To understand how this works in practice, let's give a few examples. We start from the three methods that are used today to deduct the Reynderstaks.

1. TIS value

The purest calculation of the Reynderstaks is based on the TIS value. This is the part of the asset value that includes the fund's income from fixed income securities. Just like the inventory value, the TIS value is calculated daily. When the fund is sold, the TIS value is reduced by the TIS value when purchased. This then applies to 30 percent of the Reynders' tax.

To calculate the new 10 percent capital gain tax, the full capital gain will first be reduced by the TIS capital gain. The 10 percent capital gain tax is then deducted from that difference.

Preview

On 1 January 2026, an investor buys a mixed capitalization fund (25% bonds and 75% stocks) for 150 euros. The TIS value at that time was 10 and he sold his fund for 250 euro on 30 June 2028. The TIS value is currently 20.

The capital gain under the new capital gains tax is 100 euro (250-150). Of this, 10 euro (20-10) comes from the increase in the TIS value. The 10 is taxed by the Reynderstaks at 30 percent: 3 euro.

The remaining 90 (100-10) will be taxed at 10 percent: 9 euro. Reynder tax and capital gains tax then amount to 12 euro (9+3).

Please note: if you had already purchased the fund in 2025 or earlier, you will also pay Reynderstaks on the bond capital gain you realised before 1 January 2026. You do not pay capital gains tax on the other capital gain before 2026.

2. Fall-back method

Almost all Belgian fund houses calculate a Belgian TIS value because the Belgian market is their main market. But that is not the case for the many foreign fund houses that offer their funds in Belgium.

For these funds, they will often make no effort to calculate such a Belgian TIS value on a daily basis.

In that case, the calculation of the Reynders tax must be based on the asset test. It measures the average percentage of fixed income securities in the fund over the past year. This can then be used to calculate an approximation of the bond capital gain, necessary to deduct the Reynders tax.

Preview

Suppose a fund invests 30 percent in fixed income products and you sell the fund with 100 euros of capital gain. Then, based on the asset test, it is assumed that 30 euros (30% of 100 euros) of added value comes from fixed income securities. You will then pay 9 euro Reynderstaks (30% of 30 euro). The calculation of the 10 percent capital gain tax is then calculated on the part of the capital gain that was not taxed by the Reynderstaks. In this example, that is 70 euro (100-30 euro). You then pay 10 percent capital gain tax on 70 euros, which is 7 euros.

3. Full added value

Most foreign fund houses charge an asset test annually, but there are exceptions. In the absence of both a TIS value and an asset test, the distributors must then apply the Reynderstaks to the full capital gain of the fund, even if part of the capital gain comes from the share section.

Preview

Let's say you buy a fund for 100 euros in early 2026. Eight years later, you sell the fund for 200 euros. The fund does not calculate a TIS value and there is also no asset test. In that case, the Reynderstaks will be calculated on the full capital gain. That then means 30 euros Reynderstaks (30% of 100 euro), even if the fund invests 50 percent in stocks, for example. The result, however, is that no more value tax of 10 percent has to be paid. After all, the entire added value has already been subject to the Reynderstaks.

The simple examples illustrate that the calculations will involve a lot of complexity and exceptions, especially if negative values on the stock section also come into play. With mutual investment funds, a legal structure that is tax transparent, there is a risk that income will still be taxed twice.

3/ DBI funds

The De Wever government is also nibbling on the tax advantage of the DBI funds, which allow entrepreneurs to invest in equity funds in a tax-advantageous way. DBI stands for Definitive Taxed Income. The DBI deduction is an exemption scheme that exempts companies, subject to conditions, from taxes on income from companies in which they invest and that have already been taxed. Specifically, companies that invest in DBI funds can exempt from tax both the capital gain and the withholding tax on the dividends of the funds.

The 40 DBI funds on the Belgian market contain around 10 billion euros, which shows that the funds are popular. The De Wever government intervenes on the tax advantage of the funds.

One measure, a 5 percent capital gain tax on sales, will not be felt in practice. This has to do with the technical definition of sales. Entrepreneurs who sell the shares of their FBI funds do not do so to a counterparty, but it is the DBI fund itself that purchases those shares. Because such purchasing falls outside the scope of the law, entrepreneurs who sell their DBI funds will in principle escape the 5 percent tax.

The entrepreneurs will feel the second measure. From now on, they will only be able to deduct the withholding tax on the dividends if their company applies the minimum managerial remuneration. This means that the company pays at least one director or manager an annual salary of at least 45,000 euros. From 2026, that threshold will be increased to 50,000 euros.

Companies that are already above the threshold do not have to do anything, although there is an important condition. The salary must be paid to a physical person, not to the company of the manager or director. In other words, companies where all directors are remunerated through their own management or director's company usually do not meet that additional condition. Those companies will no longer be able to settle the withholding tax.

Companies where one or more directors are paid personally, but whose remuneration is less than 45,000 euros, have the choice.

Or they raise the salary and can continue to deduct the withholding tax. For the government, this results in more taxes on wages. Or they will not raise the salary and will no longer be able to deduct the 30 percent withholding tax. This group undoubtedly also includes many management companies that invest in DBI funds and whose founder pays himself a low wage. Every company must consider the best choice.

There is, however, an important caveat. If the company makes little profit, the minimum remuneration must be at least equal to the net profit in order to be able to offset the withholding tax. For companies that, for example, make 40,000 euros in profit before deduction of remuneration, it is sufficient that they paid 20,000 euros in salary for that year to be able to settle the withholding tax. After all, the net profit is then equal to the minimum remuneration, namely 20,000 euros.

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References

• Source: De Tijd
• Link: https://www.tijd.be/markten-live/fondsen/portefeuille/wat-verandert-aan-de-fiscaliteit-van-uw-fonds-en-etf/10625190.html
• Author: Peter Van Maldegem
• Date: 23/09/2025