DBI-Beveks and the coalition agreement

The coalition agreement

FDI beveks are investment vehicles specifically designed for Belgian companies to take advantage of the FDI exemption. The proposals in the federal coalition agreement 2025-2029 have proposed significant changes that present both opportunities and concerns for companies.

Of course, this is only based on the coalition agreement, and the effective laws may differ from the coalition agreement.

What are DBI-Beveks?

FDI beveks (investment companies with variable capital) are funds in which companies can invest to benefit from the FDI exemption. This means that dividends received from qualifying shares can be exempt from corporate income tax under certain conditions. This promotes tax neutrality and avoids double taxation.

Tax benefits for management companies

1. Corporate income tax exemption: companies can receive dividends from FDI sicavs without being subject to corporate income tax, provided the distribution conditions are met.
2. Efficient cash flow planning: The exemption allows dividends to be added net to reserves, contributing to an efficient capital structure and providing more flexibility for reinvestment or distribution to shareholders.

These important changes are in the coalition agreement

In recent months there was some uncertainty whether the FDI regime would remain in place but FDI Beveks remain a tax attractive option for companies! According to the new coalition agreement, there are some significant changes specifically for FDI-Beveks:

• Levy on capital gains on exit: A 5% levy will be introduced on capital gains on exit from FDI sicavs. This reduces the tax advantage in short-term investments, and in this way we are actually going back to pre-2018 legislation.
• Limitation of withholding tax: The creditability of withholding tax against corporate income tax is now only possible if the receiving company grants the minimum managerial remuneration in the year of distribution. However, this has been increased from EUR 45,000 to EUR 50,000.

Key Components:

• Investment portfolio structure: Provide an investment strategy where you can take full advantage of the FDI scheme, taking into account the new levies.
• Long-term perspective: Given the charge for capital gains on exit, it is advisable to approach FDI beveks with a long-term horizon.
• Compliance and administrative requirements: Stricter regulations require accurate documentation and compliance to ensure tax optimization.

Conclusion:

‍Investingin FDI-beveks through the company remains a tax attractive strategy, and not much is changing (for now) in terms of FDI-beveks legislation. Of course, we will keep you informed as soon as the effective legislation becomes clearer.

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