Belgium

CIT ~25% Pillar Two ✓

25% headline rate. Strong payroll-side support for R&D employers (80% withholding tax exemption for researchers) and one of the lowest effective IP-income rates in the EU via the innovation income deduction. imec in Leuven is a world-leading R&D anchor.

✓ 3 Jul 2026

Instruments (4)

Payroll exemption Active Rule-based entitlement

Partial withholding tax exemption for R&D personnel

Employers of qualifying researchers may retain 80% of the professional withholding tax on their salaries instead of remitting it — an immediate, rule-based reduction of R&D labor cost of roughly 15–20%.

Exemption rate: 80% of the professional withholding tax remittance
Eligible degrees: Doctoral/master degrees (full rate); bachelor degrees eligible but capped
Qualifying fields: Applied/exact sciences, engineering, medical & veterinary science
Preliminary condition: Project/programme notified to BELSPO before start (mandatory)

✓ 3 Jul 2026

IP box Active Rule-based entitlement

Innovation Income Deduction (Innovatieaftrek)

Belgium's nexus-conform IP regime: an 85% deduction of qualifying net innovation income, yielding an effective rate below 4% — one of the lowest in the EU. Covers patents and, notably for chip design, copyrighted software.

Effective rate on qualifying IP income: ~3.75%
Deduction: 85% of net qualifying innovation income
Nexus conformity: Yes — deduction scaled by the nexus ratio
Qualifying IP: Patents, SPCs, copyrighted software (incl. chip-design software), plant-breeder & orphan-drug rights

✓ 3 Jul 2026

Expat tax ruling Active Rule-based entitlement

Special tax regime for inbound taxpayers & researchers

Belgium's expat regime for employees recruited from abroad: the employer can pay a tax-free allowance of up to 35% of gross remuneration, with the €90,000 cap repealed. A lever for relocating senior design staff and researchers.

Tax-free allowance: Up to 35% of gross remuneration (since 1 Jan 2025)
Cap: Former €90,000 cap repealed
Minimum salary: €70,000 (not required for the researcher track)
Duration: 5 years (+3 years extension possible)

✓ 3 Jul 2026

R&D tax credit Active Rule-based entitlement

Investment deduction (incl. technology/R&D)

A deduction (or, for R&D, an alternative tax credit) on qualifying investments, modernised from 2025 into a three-track system with an enhanced "technology" track for R&D and environment-friendly assets.

Tracks (from 2025): Basic · targeted/technology (higher) · technology deduction
R&D option: One-off deduction or a spread R&D tax credit (creditable/refundable)
Base: Qualifying capitalised investments (incl. R&D assets)

✓ 3 Jul 2026⚠ Verify pending

Ecosystems

Leuven

Leuven, Flemish Brabant

LogicAdvanced PackagingPhotonicsMEMS / SensorsAI accelerators

imec is the single strongest R&D-cooperation anchor in Europe: companies can work with advanced nodes without owning a fab.

imec — World-leading nanoelectronics R&D center; sub-2nm pilot line, IC-link MPW shuttle services for fabless design.
KU Leuven — MICAS lab — top analog/RF design group in Europe.

FDI screening & export control

⚠ Semiconductors in scope

Threshold: 10% voting rights for technologies essential to public security/defence (incl. semiconductors); 25% for general critical infrastructure
Authority: Interfederal Screening Mechanism (federal + regional cooperation)
Timeline: Not centrally published; build in several weeks to months for a full assessment

Semiconductors sit in the lower-threshold "essential for public security and defence" category. The EU-level FDI screening reform (political agreement Dec 2025) designates semiconductors a "hyper-critical technology" that all member states will be required to screen, which is expected to prompt further adjustments here.

Legal basis: Cooperation Agreement of 30 November 2022; federal FDI screening mechanism in force since July 2023 — source ↗ ✓ 3 Jul 2026

Labor law snapshot

Works council: Works council (ondernemingsraad/CE) mandatory at 100+ employees; CPBW/CPPT (health & safety committee) at 50+
Notice periods: Governed by the 2014 unified status law — notice periods scale with seniority and are comparatively long by EU standards
Bargaining: Sector joint committees (paritair comité) set binding sector-wide minimum terms — the metal/electronics joint committees (209/210-adjacent) are typically relevant for semiconductor employers

✓ 3 Jul 2026 · orientation only, verify with local counsel

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