Investing in fiscally interesting DBI funds or DBI beveks

What does DBI mean?

DBI stands for Definitive Taxed Income and is an exemption scheme for companies that investing in individual shares of other companies. Dividends and capital gains from these investments must, however, respect certain conditions in order to be exempt from (double) taxation.

The DBI exemption allows companies to exempt dividends from their subsidiaries from corporate tax, provided that three cumulative conditions are met:

Participation condition

The recipient company must hold at least 10% of the capital of the distributing company on the date of granting or making the dividends payable, or maintain an acquisition value of at least 2.5 million euros in the participation.

Permanence condition

The investing company must hold its participation for at least 1 year

Taxation condition

The distributing company must be subject to a tax regime that is similar to Belgian corporate tax.

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How can I benefit from the DBI regime as a (small) company? The DBI order

A DBI cavek is an investment fund with a tax-favourable regime for your company. By investing as a company in a DBI cavek, you can benefit from the DBI deduction on both dividends and capital gains when selling the SICAV, without the above conditions.

In doing so, the company is entitled to the DBI deduction of a maximum of 100%, insofar as it comes from companies subject to corporate tax or similar foreign tax. A 100% exemption is therefore not always guaranteed but is often approached in practice.

What are small or large companies?

Small companies are companies with legal personality that, at the balance sheet date of the last financial year closed, do not exceed more than one of the following criteria:

Turnover: 11,250,000 EUR
Balance sheet total: 6,000,000 EUR
Staff: 50 FTE

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What are the risks?

As with any stock cavek, investing in DBI beveks means that you are subject to fluctuations in the value of the fund, but you may also have a better long-term return outlook.
DBI beveks have no fixed return, no capital protection and no maturity date.

What are the new tax rules for companies? (Program Act)

The tax part of the draft Programme Act has now been adopted by the federal government. The new rule applies from tax year 2026 (for financial years starting on or after 1 January 2025).

Purpose of DBI: avoid double taxation on share dividends (DBI = “permanently taxed income”).

Regulations from tax year 2026: the favourable regime remains, but direct equity participations (i.e. outside a DBI cavek) are becoming stricter for large companies: the participation must qualify as a financial fixed asset in terms of accounting, although the minimum limit remains €2.5 million. This does not apply to DBI caveks. For small companies, there is no change.
Liquidity & diversification: you invest “packaged” in a fund with broad diversification and daily tradability, instead of managing individual stock positions.
Dividends & cash flow: Every year, DBI caveks pay out at least 90% of their net income (stable cash to your company). This deducts 30% withholding tax, which is in principle deductible and refundable. Prerequisite from tax year 2026: your company grants minimum managerial remuneration; otherwise, the settlement (or refund) may be refused.‍
Capital gains: will in principle be 95% exempt from exiting via the secondary market from 2026, but this will rarely be the case in practice.

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