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For certain new investments, entrepreneurs can apply the tax benefit of the investment deduction. A specific percentage of the investment can then be deducted from the taxable profit. The investment deduction for fixed assets acquired or realised as of 1 January 2025 will undergo a thorough reform. Specifically, qualifying investment assets will be aligned with current and future sustainable transition needs, procedural aspects will be streamlined, and annually indexed rates will be replaced by fixed rates. The federal government is now introducing the necessary implementing provisions.
Reformed Investment Deduction Categorised by 3 Fixed Percentages
In the new system, there are three categories of investment deduction, each with fixed percentages:
- The 'basic deduction'
- The 'increased thematic deduction'
- The 'technology deduction'
The applicable rates as of 2025 are summarised as follows:
| New Investment deduction for Investments acquired or realised as of 01/01/2025 | SME or natural persons | Large companies |
|---|---|---|
| Basic deduction for investments not excluded based on the climate and environmental exclusion list – one off | 10 % | / |
| Doubled basic deduction for ‘digital investments’ – one-off | 20 % | / |
| Increased thematic deduction – one-off (*) 1. Energy investment list (efficient energy use and renewable energy); 2. Transport investment list (carbon emission-free transport); 3. Environmentally friendly investment list (other than for transport or energy, such as an exhaust ventilation system in hospitality establishments, more efficient water usage, etc.) 4. Investment list for digital support (related to the investment categories mentioned under points 1 to 3). | 40 % | 30 % |
| Technology-deduction for patents and environmentally friendly investments in R&D - one-off | 13,5 % | 13,5 % |
| Technology-deduction for environmentally friendly investments in R&D - spread | 20,5 % | 20,5 % |
| Seagoing vessels (only for companies) – one-off | 30 % | 30 % |
(*) Thematic deduction: investments that comply with the lists established per theme by the Council of Ministers (for the entire Belgian territory), which are updated every three years.
Note: These deductions cannot be combined. A choice must be made when an investment meets the criteria for multiple categories.
To calculate the investment deduction, support in the form of an exemption from the payment of payroll withholding tax is not included in the calculation base.
The existing rules for transferability remain in place. In personal income tax, unused basic investment deductions are indefinitely transferable, while in corporate tax, they are transferable for one year only. For other investment deductions, unlimited transferability applies in both personal and corporate taxation.
Digital Fixed Assets (Doubled Basic Deduction)
Digital fixed assets include software and equipment that support digital payment and invoicing systems (e.g., registered cash systems), digital accounting systems, digital CRM systems, digital e-commerce platform systems, and digital systems for information and communication technology security (e.g., GDPR compliance).
Excluded from the Basic Deduction: ‘Climate- and Environment-Unfriendly Investments’
These exclusions aim to prevent investments with negative environmental or climate impacts. Specifically, investments that are no longer justified due to the availability of more sustainable alternatives (e.g., choosing a gas boiler instead of electric heating or heat pumps) are targeted.
The published exclusion list (Annex II quater to RD/CIR92) reflects efforts to phase out fossil fuels, harmful chemicals, and destructive environmental techniques while promoting sustainable investments. This exhaustive list will be periodically updated without a fixed validity period.
Thematic Investment Lists
The four thematic investment lists (Annexes to RD/CIR92), detailing fixed assets eligible for increased thematic deductions, are updated every three years. If a list is not renewed within this period, new investments cannot benefit from the applicable increased thematic deduction until a new list is published.
The lists are structured into groups of investments, further subdivided into specific categories.
All lists specify:
- Investments with a "value of less than €1,000" are excluded.
- If the total tax benefit of the investment deduction combined with other government support exceeds €30 million, the application for the deduction must be submitted for prior approval as compatible state aid to the European Commission.
Obligations (Forms, Application Procedures, and Certificates)
The government has clarified the obligations taxpayers must meet to qualify for the reformed investment deduction:
- Basic Deduction: submit form 275U or 276U with the tax return.
- Increased Thematic Deduction: Investments must appear on the 'investment list' and require a motivated certificate from the competent regional or federal authority, which must be attached to the tax return. For multi-year projects, an 'investment certificate' (per investment list) may also be requested based on the applicable lists for the taxable period in question. This latter certificate assesses the conformity of the investment based on the applicable investment lists at the time of the application.
- Technology Deduction: a certificate from the competent regional authority, including justification, is required and must be attached to the tax return.
Applications for certificates must include a detailed description of the investment, financing plans, and an estimate of costs and duration. The competent minister or delegated body must issue a motivated certificate or investment certificate within six months of the application.
Certificates must be requested "within three months after the last day of the taxable period in which the fixed assets were acquired, realised, (and respective ‘in which the investment project commenced’ for multi-year projects)." Late submission may result in the loss of deduction rights.
Entry into Force and Transitional Arrangements
The new scheme will apply to fixed assets acquired or realised as of 1 January 2025. A transitional arrangement is in place for 'ongoing investments.' Thus, the 'spread' investment deduction can still be applied to investments made before 1 January 2025, with depreciation periods extending beyond that date.
If you would like to receive additional information on this matter or require tax assistance, don’t hesitate to reach out to our RSM Belgium Tax via [email protected]
