Tax · SRL dividends · 2026

SRL dividends: withholding tax, VVPRbis and the liquidation reserve

Three schemes coexist in 2026: standard withholding tax at 30%, VVPRbis at 18%, and the liquidation reserve at an effective 18%. Choosing well can save €15,000 on €100,000 distributed.

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By the Finances Indépendants editorial team

Withholding tax on dividends: the 2026 rates

In 2026, three rates of withholding tax on movable income coexist for dividends paid by a Belgian SRL, depending on the applicable scheme:

Withholding tax rate

Conditions

Total cost with corporate income tax

Standard withholding tax

30%

None (default scheme)

47.5% (on profit before corporate income tax)

VVPRbis

18%

SME cash contribution, registered shares, 3rd financial year onwards

38.5%

Liquidation reserve

10% + 9.8% after 3 years

Profit held in reserve for 3 years before distribution

38.5%

Source: Income Tax Code 1992 · Art. 269 CIR · 2026

VVPRbis: the 18% scheme

The VVPRbis scheme (Verlaagde Voorheffing op Roerende Inkomsten, reduced withholding tax on movable income) is an exception to the standard withholding tax introduced to encourage share-capital financing of SMEs. It lowers the withholding tax on movable income to 15% under four strict conditions:

  • The company qualifies as an SME within the meaning of Article 1:24 of the Companies and Associations Code (CSA)
  • Cash contribution (not in kind) made after 1 July 2013
  • Registered shares fully paid up on issue
  • Held in full ownership since issue (no intermediate transfer)

The applicable rate is progressive: 30% in the first year, 20% in the second, then 18% from the third financial year following the contribution. This last rate was 15% until 30 June 2026: the programme law of 30 May 2026 raised it to 18% for dividends distributed from 1 July 2026, to align it with the liquidation reserve rate.

The liquidation reserve: the ultimate lever

The liquidation reserve is the most efficient mechanism for gradually taking cash out of an SRL with optimal taxation.

When the financial year closes, the company can allocate all or part of its net accounting profit to a 'liquidation reserve'. This allocation triggers an immediate 10% separate levy payable by the company. If the capital stays in reserve for 3 years, the later distribution bears 9.8% withholding tax on movable income, i.e. a total burden of 18%.

Three schemes coexist, and it is the closing date of the financial year in which the reserve was created that counts, not the distribution date. A reserve created in a financial year closed before 31 December 2025 keeps the choice between 5 years at 5% (13.64% in total) and 3 years at 6.5% (15%). A reserve created in a financial year closed on or after 31 December 2025 falls solely under the 3-year, 9.8% scheme. A distribution before the end of the waiting period falls back to the ordinary rate.

Profit after 25% corporate income tax: €75
= Liquidation reserve: €68.18
− Separate levy of 10% of the reserve: €6.82
3 years later:
Distribution: €68.18
− Withholding tax 9.8%: €6.68
= Net in your pocket: €61.50 (vs €52.50 as a standard dividend)

On €100 of profit before corporate income tax, the difference between a standard dividend (€52.50 net) and the liquidation reserve after 3 years (€61.50 net) is 9 points of gross profit. On €1M of profit, that is €90,000 of extra net income, available two years earlier than before the 2025 reform. Note: since the two schemes were aligned on 1 July 2026, the liquidation reserve and VVPRbis lead to exactly the same net amount. The choice now depends on the eligibility conditions and the time horizon, no longer on the rate.

Salary vs dividend: the 2026 trade-off

An SRL director must first pay themselves €50,000 of regular annual remuneration for the company to benefit from the SME corporate income tax rate of 20% (instead of 25%). Below that, the 25% rate applies to all profit, and the saving on remuneration is cancelled out by the higher corporate income tax.

Above €50,000 of salary, the trade-off becomes gradual: each extra euro of salary is subject to social security contributions (~20.5%) + marginal personal income tax (~50%), whereas as a dividend it bears corporate income tax (20% or 25%) + withholding tax (15-30%).

See the 80% rule: your remuneration also determines your pension envelope (IPC).

When to distribute a dividend

A dividend distribution follows a formal procedure: (1) close of the financial year, (2) approval of the accounts by the general meeting, (3) distribution decision based on an audited balance sheet, (4) payment and declaration of the withholding tax on movable income to FPS Finance within 15 days.

Since the 2019 Companies and Associations Code, two tests are mandatory before any distribution: a liquidity test (can the company pay its debts over the next 12 months?) and a net asset test (do the net assets remain positive after the distribution?).

Worked example: taking €50,000 out of an SRL

Let's compare the three schemes for a director who wants to take €50,000 net out of their SRL in 2026, with profit before corporate income tax available.

Profit needed before corporate income tax

Corporate income tax

Withholding tax

Net to director

Dividend at 30%

≈ €95,240

€23,810 (25%)

€21,430

€50,000

VVPRbis at 18%

≈ €81,300

€20,325 (25%)

€10,975

€50,000

Liquidation reserve (3 years)

≈ €81,300

€20,325 (25%)

10% + 9.8% = €10,975

€50,000

Indicative estimate. Actual calculation to be confirmed with your accountant.

Saving achieved by moving from standard withholding tax to the liquidation reserve: ~€14,000 less profit needed before corporate income tax, i.e. almost a year of extra pension contributions for the same net result.

Sources

  1. Income Tax Code 1992, Articles 184-184quater (liquidation reserve), 269 (withholding tax) CIR. View (new tab)(Official source, 2025)
  2. Companies and Associations Code (CSA 2019), Articles 5:142 et seq., distribution of SRL dividends. View (new tab)(Official source, 2019)
  3. FPS Finance, 2024 circular, withholding tax on dividends 2025-2026. View (new tab)(Official source, 2024)

SRL dividends, 2026 figures

Three schemes, three costs

  • 30%

    Standard withholding tax on movable income

    CIR Art. 269 · 2026

  • 15%

    VVPRbis withholding tax (SME, 3rd financial year onwards)

    CIR Art. 269 §2 · 2026

  • ≈ 18%

    Total burden via the liquidation reserve or VVPRbis, after 3 years

    CIR Art. 184quater · 2026

Dividends FAQ

Frequently asked questions about SRL dividends

  • The standard rate is 30%. The VVPRbis scheme lowers it to 18% subject to conditions (cash contribution to an SME, fully paid-up registered shares, distribution from the 3rd financial year after the contribution). Source: Article 269 CIR.

  • When the financial year closes, the company pays a 10% separate levy on the net profit allocated to the 'liquidation reserve'. The waiting period is 3 years. For reserves created in a financial year closed on or after 31 December 2025, the withholding tax on distribution is 9.8%, i.e. a total burden of 18%. Earlier reserves keep the choice between 5 years at 5% (13.64%) and 3 years at 6.5% (15%).

  • The company qualifies as an SME (Art. 1:24 CSA), a cash contribution made after 1 July 2013, fully paid-up registered shares, held in full ownership since issue. The rate drops to 20% from the 2nd financial year, then 15% from the 3rd.

  • An SRL director must first take €50,000 of annual remuneration to benefit from the SME corporate income tax rate of 20%. Above that, the dividend gradually becomes more attractive than salary (savings on social security contributions and on the marginal personal income tax rate). The liquidation reserve makes dividends particularly attractive over 5 years or more.

  • On €100 of profit before corporate income tax, €75 remains after 25% corporate income tax. After 30% withholding tax on distribution, 75 × 0.70 = €52.50 net remains in the director's pocket. That is a combined tax cost of 47.5%.

  • Not on the same slice of profit. Either you distribute under VVPRbis from year 3 at 18%, or you place profit in the liquidation reserve for 3 years for 18% in total. Since 1 July 2026, both schemes cost the same. The choice depends on when you want to take cash out and on your need for immediate liquidity.