Investing in tax-efficient DBI funds or DBI investment companies

What does DBI mean?

DBI stands for Definitief Belaste Inkomsten (Definitively Taxed Income) and is an exemption scheme for companies that invest in individual shares of other companies. Dividends and capital gains from these investments must meet certain conditions in order to be exempt from (double) taxation.

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

Participation requirement

On the date of allocation or payment of the dividends, the receiving company must hold at least 10% of the capital of the distributing company, or maintain an acquisition value of at least €2.5 million in the participation.

Permanence condition

The investing company must hold its participation for at least one year.

Appraisal condition

The paying company must be subject to a tax system comparable to Belgian corporate income tax.

At Value Square, we have the right DBI experts on board.

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

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

In this case, the company is entitled to the DBI deduction of up to 100%, to the extent that it originates from companies subject to corporate income tax or similar foreign tax. A 100% exemption is therefore not always guaranteed, but in practice it is often approached.

What are small or large companies?

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

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

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What are the risks?

As with any equity mutual fund, investing in DBI mutual funds means that you are subject to fluctuations in the value of the fund, but you may also have better long-term return prospects.
DBI mutual funds have no fixed return, no capital protection, and no maturity date.

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

The tax section of the draft Program Law has now been adopted by the federal government. The new rule will apply from the 2026 tax year (for financial years starting on or after January 1, 2025).

Purpose of DBI: to avoid double taxation on dividends from shares (DBI = "definitively taxed income").

Regulations from the 2026 tax year onwards: the favorable regime will remain in place, but direct shareholdings (i.e., outside a DBI-bevek) will become stricter for large companies: the holding must qualify as a financial fixed asset for accounting purposes, and the minimum threshold may also be increased from €2.5 million to €4 million. This does not apply to DBI-beveks. There is no change for small companies.
Liquidity & diversification: you invest in a fund with broad diversification and daily tradability, rather than managing individual stock positions. (p.1–2)
Dividends & cash flow: DBI-beveks pay out at least 90% of their net income annually (stable cash flow to your company). A 30% withholding tax is deducted from this, which in principle is offsetable/refundable. Condition from AJ2026 onwards: your company must pay a minimum salary to its managers; if not, the offset (or refund) may be refused.
Capital gains: from 2026 onwards, these will in principle be 95% exempt when exiting via the secondary market, but in practice this will rarely be the case.

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