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Can directors claim a royalty from their company ?

In Belgian tax law, there is a very favourable tax regime for personal income resulting from the transfer or assignment of copyrights, provided that some specific conditions are met. While normal professional earnings are subject to the standard progressive tax rates (25% up to 50%), plus social security, this type of income is classified as ‘movable’ income up to €73,070 (tax year 2025), which is taxed at only 15% and not subject to social security.

In actuality, the tax burden is even lower, because the beneficiary can benefit from certain lump sum expense deductions on the royalty payments. Here are the relevant deductions for income year 2024 (tax year 2025):

Royalty incomeExpense deductionTaxable amountIncome tax due
€0 – €19,48050% (€9,740)€9,740€1,461
€19,480 – €38,97025% (€4,872.5)€14,617.5€2,192.6
€38,970 – €73,0700%€34,100€5,115
> €73,070  standard progressive tax rates

If the taxpayer receives €73,070 in royalties in 2024, he will pay a total income tax of only €8,768.6. Any payment above that threshold is considered to be professional income, taxed at the above-mentioned progressive tax rates and subject to social security.

Initially, the intention was to limit this favourable regime to income generated within a more ‘artistic’ context (e.g. architects, graphic designers, journalists, etc.). Its scope quickly became wider than that and basically extended to any type of creation that can benefit from copyright protection. This is the case if the work is: (i) ‘original’ (the expression of the author’s personal intellectual creation), and (ii) ‘materialized’ in a concrete, visible or audible form.

In view of this, a director or manager who provides services through their own management company could potentially benefit from the royalty tax scheme, as long as they are the author of some type of copyrighted work. To avoid improper use, the tax authorities introduced some guidelines to further limit the scope. While no specific sectors or professions have been excluded, there is no exhaustive list of who is eligible nowadays, which creates uncertainty.

The beneficial regime is only accessible if you can present a ‘work of art’ certificate or can demonstrate that the copyrights have been transferred or licensed to a third party for communication to the wider public, for public performance or for reproduction. If services are rendered as well, the ratio of royalty to total remuneration must not exceed 40% (2024). Next year (2025) this will be further reduced to 30%. Some further restrictions apply.

TAXPATRIA® can check if your company is still eligible to implement a royalty payment scheme.


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