VVPRbis Dividends: How Belgian Small Company Owners Pay Themselves at 18% — and What Changed in July 2026

If you own a Belgian BV or SRL, your tax bill on the money you take out of the company is one of the highest you will ever pay. Salary is taxed at progressive rates approaching 50%. Director's fee adds social security on top. The single most popular legal way around this — used by tens of thousands of Belgian small business owners — is called VVPRbis.

This guide is for you, the founder. Your accountant will run the actual numbers. But you should understand what is being done with your money.

What VVPRbis actually does

You created your BV. You put cash into it as starting capital — let's say €18,600 (the legal minimum for a BV is now zero, but most founders contribute something). The company makes profit. After corporate tax, that profit sits as retained earnings.

You want to take some of those retained earnings home.

Without VVPRbis, the company pays you a dividend taxed at 30% withholding. €100,000 dividend → €30,000 to the state → €70,000 to you.

With VVPRbis, the same dividend is taxed at 18% — it was 15% until 30 June 2026. €100,000 dividend → €18,000 to the state → €82,000 to you.

On a €100,000 distribution, that is €12,000 more in your pocket. On a typical founder's career of 15–20 years of small dividends, the saving easily reaches €200,000+.

The four conditions you must meet

1. Your company has to be "small". Belgian law has a precise test, but in practice if your annual turnover is under €11.25 million and you have fewer than 50 employees, you are small.

2. Your starting capital has to be cash. Contributions of equipment, IP, or property do not count. If you put €30,000 in cash into the company on day one, that €30,000 qualifies. If you transferred €30,000 of software, it does not.

3. You have to wait three full years. If you formed the company in 2023, the first VVPRbis-eligible distribution is in 2026 (third full year). Earlier distributions get the standard 30%.

4. No fancy share classes. If you set up Class A shares with extra voting rights and Class B shares with extra dividend rights, you broke the rules. Stick with one ordinary share class.

What changed in July 2026

The favourable rate went from 15% to 18%. The law is the Programme Law of 30 May 2026; it appeared in the Belgian Official Gazette on 1 June 2026 and took effect on 1 July 2026, for dividends attributed or made payable from that date. It harmonises VVPRbis with another small business tool, the liquidation reserve.

What this means now: the three-point saving is gone. It applied to dividends attributed or made payable up to and including 30 June 2026, and the date that counted was the date the dividend was attributed or made payable — not the date of the general meeting. If a dividend of yours was resolved in June but only paid in July, it withholds 18%, and the declaration has to say so.

A realistic example

You formed a Belgian BV in 2022 with €30,000 cash. You have grown to €600,000 annual revenue, you pay yourself a €40,000 director's fee, and the company has accumulated €180,000 in retained earnings.

In May 2026, while the 15% rate still applied, you distributed €60,000 as a VVPRbis dividend.

• Tax: 15% × €60,000 = €9,000
• Net to you: €51,000

If you had taken the same €60,000 as additional director's fee:

• Personal income tax (top marginal slice): ~50% = €30,000
• Social security (self-employed): ~20% = €12,000
• Net: ~€18,000

The dividend route nets you €33,000 more, on this single distribution. Repeat it today and the withholding is 18% — €10,800 instead of €9,000 — which barely dents the comparison.

The combined strategy most savvy founders use

The smartest Belgian founders combine three tools:

1. Modest director's fee — covers daily life, builds your pension and unemployment insurance.
2. VVPRbis dividend annually from year 4 onwards — moves retained profit out at 18% (15% up to 30 June 2026).
3. Liquidation reserve on remaining retained earnings — appropriate now, 10% separate assessment up-front, distribute at 9.8% after a three-year holding period, or at exit.

The combined effective rate on profit taken out of your company lands around 25–30% — versus 60%+ if you took everything as salary.

What can go wrong

• Your accountant uses the wrong rate. Easy mistake in year 3 — 20% survives only where your cash contribution was made on or before 31 December 2025. And check the rate against the date the dividend was attributed or made payable, not the date of the resolution.
• You convert your capital before the wait period. A capital reduction restarts the clock for new contributions.
• You sell the company. Selling shares is a separate regime (capital gains, currently exempt for natural persons in most cases — subject to the new 2026 capital gains tax for >€10m transactions).
• You forget to declare the withholding on time. The 273A form is due within 15 days of payment. Late filing triggers fines.

The one-page action plan

1. Check with your accountant the date of your original cash contribution and your current "year + N" status.
2. Confirm the company still meets the small-company test for the past two financial years.
3. Decide the amount of dividend you want to take this year, leaving sufficient working capital.
4. Schedule the general assembly approving the dividend.
5. Pay knowing the rate follows the date the dividend is attributed or made payable. Since 1 July 2026 that is 18%; 15% applied only up to and including 30 June 2026.
6. File the 273A withholding declaration within 15 days.

That's VVPRbis. Less mysterious than it sounds. More valuable than most founders realise.