On 11 December 2025, the Belgian Parliament approved several important amendments to the reformed investment deduction.
Key changes
The core elements of the reform are:
- Cumul with regional aid no longer prohibited (insofar as the regional aid itself may be combined);
- Abolition of caps on carry-forward deductions;
- Basic deduction can be carried forward indefinitely in time;
- Thematic deduction of 40% for all companies as from A.Y. 2027.
Cumul with regional aid allowed – but cumul works both ways
Investments for which regional aid has been requested are no longer excluded from the thematic deduction.
However, the possibility of combining different support measures must be assessed from all angles.
For example: in Flanders, GREEN investment aid and the Ecology Premium+ may not be combined with other support measures, including the investment deduction.
Therefore, always verify the conditions attached to regional subsidies before submitting an application or combining aid.
Abolition of caps – greater fiscal flexibility
The annual caps on carry-forward deductions have been abolished, allowing for better utilisation of the benefit for large investments.
For the R&D tax credit (under the same conditions as the technology deduction), these caps remain in place.
It is still unclear whether this was a deliberate policy choice (to avoid rapid cash refunds) or a technical oversight.
Impact for SMEs and choice between deductions
Due to the unlimited carry-forward of the basic deduction, small and medium-sized enterprises (SMEs) have less need to opt for the technology deduction.
Nevertheless, the technology deduction remains attractive because of:
- The possibility of spread application (20.5%);
- The option to convert it into a refundable R&D tax credit.
A thorough comparison between the different deduction regimes therefore remains essential.
Thematic deduction – a temporary but attractive benefit
The thematic deduction provides for an increased rate of 40% for all companies as from A.Y. 2027.
However, this advantage is temporary: the investment lists are valid until 31 December 2027, with a possible extension of two years by the government.
Without an extension, the benefit will disappear after that date.
Some companies with a broken financial year may therefore only benefit from the increased rate to a limited extent.
Example: a company with a financial year running from 1 October to 30 September can only benefit from the 40% rate for 15 months (between 1 October 2026 and 31 December 2027).
Strategic recommendations
To make optimal use of the new rules, companies are advised to:
- Plan investments in a timely manner in line with the temporary lists;
- Carefully verify the possibility of cumulation with regional aid;
- Compare fiscal scenarios (technology, R&D or thematic deduction);
- Anticipate a possible extension of the measure.
Key benefits briefly
- Greater flexibility and simplicity in applying the deduction;
- Faster utilisation of carry-forward deductions;
- Generalisation of the 40% rate as from assessment year 2027.
Position your next investment strategically
The reform of the investment deduction offers new tax opportunities for companies investing in greening, renewable energy and sustainability.
By planning ahead and selecting the right combination of support measures, you can significantly increase your fiscal return.
Questions about the new investment deduction?
Our tax experts will be happy to help analyse your situation and develop the right strategy.
