A useful global summary.

The law of April 6, 2026, introducing a capital gains tax on financial assets raises important practical questions regarding dispositions that include an earn-out clause. Three major issues—identified during the legislative process—are the subject of ministerial clarifications.

The law of April 6, 2026, introducing a tax on capital gains on financial assets was published in the Belgian Official Gazette on 21 April 2026. It sets out four methods for determining the historical value of unlisted financial assets as of 31 December 2025 (Article 102, §4, 2°, of the Belgian Income Tax Code 1992, "ITC 92"). This newsletter examines the clarifications provided by the preparatory works on the practical application of these four methods.

Le 21 septembre 2023, la Cour constitutionnelle a rendu un arrêt important....