The Belgian annual securities account tax has entered a new phase. The EUR 1 million threshold is unchanged. The rate, however, has doubled — from 0.15% to 0.30% — and the legislator, through the program law of 29 July 2025, has closed several blind spots that allowed taxpayers to keep their taxable base below the threshold. For directors whose financial wealth crosses that line, the calculation now looks different.
The annual securities account tax (TACT in French; JTER in Dutch) applies to securities accounts whose average value over the reference period (1 October to 30 September) exceeds EUR 1,000,000. As of the 2026 reference period, the rate is raised to 0.30% (from 0.15%), with a cap that limits the tax to 10% of the difference between the taxable base and the threshold. The program law of 29 July 2025 introduces two rebuttable presumptions of abuse to neutralise share-register conversions and transfers between accounts. Tangible movable property — and notably artworks — remains structurally outside the scope.
When the current TACT was reintroduced by the Act of 17 February 2021, it was explicitly aimed at the most substantial financial portfolios — the EUR 1 million threshold was no accident. Five years later, the budgetary envelope it contributes to has become structural, and the federal government has decided to double its yield. The chosen method — moving from 0.15% to 0.30% — is straightforward arithmetic. But the second strand of the regime, less commented on, is probably the more important one for anyone managing a portfolio close to the threshold: the legislator is now hunting fragmentation strategies.
The fundamentals: who is taxed, on what base
The TACT is governed by Title X/1 of the Code of Miscellaneous Duties and Taxes. It applies to securities accounts held, jointly or otherwise, by natural persons (resident or non-resident), companies and other legal entities, whenever the average value of the account during the reference period exceeds EUR 1,000,000.
The average value is calculated on four reference dates: 31 December, 31 March, 30 June and 30 September. The reference period for the 2026 assessment runs from 1 October 2025 to 30 September 2026. Each snapshot is taken on those dates, and the arithmetic mean of the four readings forms the taxable base.
The base captures all taxable financial instruments held on the account: listed and unlisted shares, bonds, units in collective investment schemes, warrants, certificates, ETFs and cash balances. Holdings through a Branch 23 unit-linked life insurance contract are also within scope, via the technical account of the insurance company.
The rate and its 2026 evolution: what is changing in practice
For five years, the TACT rate was set at 0.15%. The federal budget agreement reached at the end of 2025 raised it to 0.30% as of the 2025-2026 reference period. The rationale is purely budgetary: doubling the expected yield, estimated at around EUR 400 million per year.
The calculation remains framed by a cap: the tax cannot exceed 10% of the difference between the taxable base and the EUR 1 million threshold. In concrete terms, on an account with an average value of EUR 1,001,000, the gross tax at 0.30% would be EUR 3,003 — but the cap brings it down to EUR 100, i.e. 10% of the slice above the threshold. The cap ceases to bite once the taxable base reaches approximately EUR 1,015,228, the point from which the tax is computed directly at 0.30% on the full value.
| Average account value | Tax at 0.15% (former regime) | Tax at 0.30% (2026 regime) |
|---|---|---|
| EUR 950,000 | EUR 0 (below threshold) | EUR 0 (below threshold) |
| EUR 1,001,000 | ~ EUR 100 (capped) | ~ EUR 100 (capped) |
| EUR 1,015,228 | ~ EUR 1,523 | ~ EUR 3,046 |
| EUR 1,500,000 | EUR 2,250 | EUR 4,500 |
| EUR 3,000,000 | EUR 4,500 | EUR 9,000 |
For a EUR 3,000,000 account, the annual gap is EUR 4,500. Over ten years at constant wealth, the cumulative additional cost approaches EUR 45,000. Not catastrophic — but not negligible either, particularly when stacked on top of other frictions: dividend withholding tax, stock-exchange tax, and the new 10% capital gains tax on financial assets introduced by the Arizona reform.
The new anti-abuse provisions of the program law of 29 July 2025
The least-commented element of the new regime is probably the most structural. From the inception of the TACT, the tax authorities had observed that some account holders were trying to keep their accounts below the threshold through fragmentation: opening additional accounts with other intermediaries, partial transfers, or converting financial instruments into registered shares (i.e. inscribed in the issuer's share register and no longer held on a securities account within the meaning of the law).
The program law of 29 July 2025 introduces two rebuttable presumptions of abuse — meaning that the tax authorities are entitled to treat certain transactions as motivated by tax avoidance, unless the taxpayer can demonstrate valid motives other than avoidance:
First presumption — conversion into registered form. Where the value of the account before conversion exceeds EUR 1,000,000, and where part or all of the securities are converted into registered shares without any change in the other characteristics of those securities, the transaction is presumed to be motivated by avoidance of the TACT. The converted securities are then reintegrated into the taxable base as if they had remained on the account.
Second presumption — transfer to other securities accounts. The transfer of part of the securities of an account exceeding EUR 1,000,000 to one or more other securities accounts of the same holder or co-holder is also presumed to be abusive, under the same conditions.
Belgian financial institutions are now under a duty to notify the tax authorities of transactions falling within these criteria. Any conversion or transfer that is not supported by an objective economic justification — documented wealth restructuring, gift, succession, corporate reorganisation — is exposed to recharacterisation. The presumption can be rebutted, but the burden of proof lies with the taxpayer.
Assets outside the scope: exemptions, exclusions and limits
Not every form of financial wealth falls within the scope. Several categories are explicitly excluded — either to avoid double taxation or for policy reasons.
Pension funds of the second pillar (employer-sponsored capital, IPT, VAPZ) and the third pillar (individual pension savings) are entirely exempt, regardless of size. Branch 21 guaranteed-return life insurance contracts are also outside scope: only Branch 23 contracts — linked to investment funds — are taxed, with the insurance company collecting and remitting the tax.
Registered shares inscribed in the issuer's share register — and not on a securities account — remain outside the scope, subject to the new anti-abuse provisions discussed above. This is one of the most common configurations among holders of family holding companies: shares of an unlisted entity are typically registered, and do not generate any TACT.
Finally, tangible movable property — artworks, non-monetary precious metals, fine wines, collectible watches — is structurally excluded. Such assets cannot be inscribed on a securities account within the meaning of the law, and the TACT does not target them. The same logic applies to real estate, which is governed by an entirely separate tax regime.
Asset classes whose legal nature does not allow inscription on a securities account retain their wealth characteristics. For directors who have allocated part of their wealth to tangible movable property — including artworks — the annual TACT envelope simply does not apply, neither to the existing holdings nor to subsequent movements.
Rethinking diversification: structural alternatives
For a director whose securities account exceeds EUR 1,000,000, several questions deserve to be asked together — not to escape the tax (the new anti-abuse provisions make fragmentation hazardous), but to recalibrate the weighting of asset classes against their effective tax treatment.
Donation, with or without reservation of usufruct, remains a structural tool. A gift to children, executed before a notary, shifts the taxable base to the next generation and may, depending on the architecture chosen, take a portion of the wealth out of the donor's TACT perimeter. Subject to conditions — notably a genuine, pre-existing wealth motive distinct from any avoidance approach — the operation is admitted.
Holding artworks, either personally or through a management company, follows a different logic: converting part of one's financial wealth into tangible movable property structurally outside the TACT scope, with a separate tax treatment (depreciation deductible at corporate income tax level under certain configurations, exempt private capital gain subject to the normal management of private wealth under article 90 §1 of the Belgian Income Tax Code). The regime is not a silver bullet — it requires a case-by-case analysis, careful documentation and coordination with the accountant and tax adviser.
Finally, real estate sits outside the TACT perimeter by construction. It is governed by its own tax framework — withholding tax on rental income, cadastral income, VAT where applicable — which deserves to be benchmarked against the taxation of an equivalent financial portfolio.
Three principles of coherence
First principle. No wealth restructuring should be triggered solely to avoid the TACT. The anti-abuse provisions of the program law of 29 July 2025 are designed precisely to neutralise that reasoning. The motivation must always be wealth-driven first, tax-aware second.
Second principle. Asset class diversification is not a tax sport — it is a wealth discipline. The financial portfolio retains its relevance: liquidity, current yield, market exposure. But its weighting deserves to be reassessed in the light of accumulated tax frictions (TACT + dividend withholding + Arizona capital gains + stock-exchange tax).
Third principle. Any conversion, transfer or donation should be documented in advance. Financial institutions now report to the tax authorities the transactions falling within the anti-abuse perimeter. It is far better to anticipate the wealth justification than to construct it under pressure after the event.
If you manage a securities account above the threshold and want to model the combined effect of the TACT, dividend withholding and the new capital gains tax, the first confidential meeting is there to set up the diagnosis — not to sell a single solution.