Roughly 53% effective top rate in Belgium. 10% flat in Bulgaria. 15% combined on company profits versus approximately 40% in Belgium. The gap between Belgium and Bulgaria is one of the largest inside the European Union — and since 1 January 2026, Bulgaria has been a euro country, removing the last currency friction for Belgian entrepreneurs and investors.
But a move from Belgium is not only a tax exercise. You must file a model 8 deregistration at your commune, manage the new 2025 exit tax for individual shareholders introduced under the Arizona coalition's program law, close or keep your securities account (which, above EUR 1 million, carries an annual tax), settle your mutualité cover, and plan your Belgian pension treatment under the 1988 BE-BG double tax convention. Miss a step and you risk dual tax residency and unexpected assessments from FPS Finance.
This guide walks through the full process — from your last visit to the commune to your first NRA (Bulgarian tax agency) filing. It is written by a Bulgarian law firm that handles Western European relocations regularly. Where Belgian rules are fresh from the 2024-2025 reforms, we flag them clearly and recommend you confirm details with a Belgian tax advisor.
Why Belgians Leave: The 2026 Pressure Points
Belgium has always been a high-tax country, but the last 24 months have raised the pressure. The Arizona federal coalition formed in 2025 pushed through a package of measures designed to broaden the tax base, and several directly affect mobile entrepreneurs and investors:
- Top marginal rate of 50% kicks in above roughly EUR 46,440 of taxable income (2026 brackets), plus a municipal surcharge of 6% to 9% of the federal tax depending on commune. Brussels averages 6%, Wallonia 7-8%, Flanders 7%. Effective top marginal rates routinely exceed 53%.
- A new capital gains tax on financial assets enters into force from 1 January 2026, ending Belgium's historical reputation as a capital-gains haven for "normal management of private wealth".
- A new individual exit tax was introduced by the Program Law of 18 July 2025 and applies from 29 July 2025. Leaving Belgium is no longer tax-neutral for shareholders.
- VVPRbis dividend regime under pressure — the favoured 15% reduced dividend withholding tax for SME distributions is scheduled to be harmonised upward (figures of 18% were floated in the 2026 budget framework, with the intermediate 20% rate abolished for contributions from 1 January 2026).
- The annual tax on securities accounts — currently 0.15% on balances above EUR 1 million — may double to 0.30% under the 2026-2029 budget framework.
- The copyright tax regime, long used by IT consultants and creators, was narrowed in 2023 and is being further reformed in 2026: the flat-rate cost deduction is abolished for non-artists, substantially reducing the benefit for most IT professionals and journalists.
For Belgian BV/SRL owners, founders, investors, and remote workers, the direction of travel is obvious. Bulgaria — inside the EU, now a euro country, Schengen member since January 2025 — offers the cleanest alternative in Europe.
Step 1 — Belgian Tax Deregistration (Model 8)
Belgium has no separate "tax deregistration". Your tax residency ends when you cease to be registered in the Belgian National Register as resident of a commune and your centre of vital interests actually shifts abroad. The administrative gate is model 8 (attestation de radiation / attest van afschrijving).
The model 8 process
- Report in person at your commune (gemeente / commune / Gemeinde) no later than the day before your departure. This is mandatory for EU citizens and their family members leaving Belgium permanently. Some communes accept online pre-registration; most require an in-person appointment.
- Bring your identity card and residence permit (the card is handed in), along with proof of your new Bulgarian address once available — a rental contract or hotel/Airbnb receipt in the early weeks is generally accepted.
- Receive the model 8 certificate — the official Certificate of Deregistration from the National Register. It is free of charge and can often be issued immediately or within three working days. Keep it permanently.
- Notify FPS Finance (SPF Finances / FOD Financiën) so they flag your tax file. Your Belgian tax residency ends on the effective date of departure, not the date of the commune visit.
- Notify your mutualité / ziekenfonds, your bank, your social insurance fund (for self-employed), and if you keep Belgian nationality, register with the Belgian consulate in Sofia using the model 8.
Warning: Without a model 8 and a genuine shift of your centre of vital interests, FPS Finance can continue to treat you as a Belgian tax resident — subjecting your worldwide income to Belgian progressive rates and municipal surcharges. The commune step is administrative; tax residency is substantive. Both must align.
Your final Belgian tax return
For the year of departure, you file a special return (déclaration spéciale / bijzondere aangifte) covering the period during which you were a Belgian tax resident. After that, if you keep Belgian-source income (rental income from a Belgian property, for example), you file as a non-resident on form IPP-NR.
Step 2 — The New Belgian Exit Tax (2025)
Historically, Belgium had no exit tax on individuals — which is why "emigration to Portugal/Italy/Monaco" long featured in Belgian estate planning. That changed in 2025.
The Program Law of 18 July 2025, part of the Arizona federal coalition agreement, introduced two linked measures that apply from 29 July 2025:
- A deemed dividend on corporate emigration — when a Belgian company transfers its seat abroad or undergoes certain cross-border reorganisations, shareholders are treated as receiving a deemed dividend equal to their pro-rata share of accumulated profits, taxed as ordinary dividend income (30% withholding for individuals).
- An exit tax on individual capital gains — when a Belgian tax resident individual transfers residence abroad, latent capital gains on financial assets can be taxed if the assets are actually disposed of within two years of departure. Shareholding is assessed at the individual level (family-level aggregation no longer applies).
Automatic EU deferral
For moves within the EU, EEA, or a country with a treaty providing for mutual assistance in recovery of taxes, payment of the Belgian exit tax is automatically deferred. Bulgaria qualifies on both grounds — EU member state and DTC partner — so no upfront payment is required.
Crucially, if you return to Belgium within 24 months of your departure, no exit tax is ultimately due. Only a genuine exit followed by an actual disposal of the assets within the two-year window triggers the charge.
Rules changed in 2024-2025 — confirm with a Belgian tax advisor. The exit tax, the new general capital gains tax from 1 January 2026, and the interplay between the two are still being clarified. Before moving, get a written opinion from a Belgian fiscaliste covering your specific holdings, shareholdings, unrealised gains, and planned post-move disposals. The general architecture is clear; the detail is still settling.
Practical implication
If you own shares in a Belgian or foreign company and plan to sell them shortly after leaving Belgium, you are within the Belgian net for up to 24 months. Either accept the Belgian tax (likely with credit against any Bulgarian tax), or structure the sale to fall outside the two-year window. For long-term holders who intend to keep their shares, the new exit tax is largely a reporting obligation — not a cash cost.
Belgian Exit Tax Unclear? Talk to Us First.
We coordinate with your Belgian fiscaliste and handle the Bulgarian side end-to-end.
Book Free 15-Min Call →Step 3 — Bulgaria Residence as an EU Citizen
Belgian citizens are EU citizens. You enter Bulgaria freely — no visa, no border queue (Bulgaria joined Schengen in January 2025). You may stay up to 90 days without any registration. For long-term residence, you register at the Migration Directorate (Дирекция Миграция) under the Ministry of Interior.
Important: You do not register at a police station. You do not go to GRAO. The only authority handling EU citizen residence is the Migration Directorate. That is where you receive your EU residence certificate and your LNCH (personal number for foreigners).
Four grounds for EU prolonged residence
To obtain a prolonged residence certificate (valid up to 5 years), you must prove one of four grounds:
- Company owner or self-employed — you own a registered Bulgarian EOOD/OOD or are a registered freelancer.
- Employee — you have an employment contract with a Bulgarian employer.
- Self-sufficient person — you have private health insurance valid in Bulgaria and sufficient funds (roughly EUR 5,100 for the year, or Bulgarian minimum pension equivalent).
- Family member — joining a resident spouse, partner, or parent/child.
For most Belgian relocators — BV/SRL founders, freelancers, consultants — ground 1 is the cleanest route: register a Bulgarian EOOD and use the shareholding as your basis for residence.
Fees and timeline
Residence card fees: EUR 7 for standard processing (up to 14 days), EUR 18 for fast-track (3 days), or EUR 36 for express (same day in some offices). Your LNCH number is issued with the residence card.
See also: Bulgaria Residence Permit for EU Citizens and First 30 Days in Bulgaria — Setup Checklist.
Moving from Belgium? We Handle the Full Stack.
Model 8 coordination, EOOD setup, EU residence, bank account, NRA registration. One invoice.
Book Free Consultation →Tax Comparison: Belgium vs Bulgaria (2026)
A side-by-side view of the figures that actually matter:
| Tax Category | Belgium | Bulgaria |
|---|---|---|
| Personal income tax | 25% / 40% / 45% / 50% (progressive, top from ~EUR 46,440) | 10% flat |
| Municipal surcharge | 6% - 9% of federal tax | None |
| Effective top marginal | ~53% and above | 10% |
| Corporate income tax | 25% standard (20% on first EUR 100K for qualifying SMEs) | 10% |
| Dividend withholding | 30% standard; 15% VVPRbis (reform pending) | 5% |
| Combined CIT + dividend | ~40% (25% + 30% on net) / ~36% VVPRbis | 15% (10% + 5%) |
| Capital gains (financial assets) | New tax from 1 Jan 2026 | 10% (0% on EU-regulated market shares) |
| Self-employed social security | ~20.5% of net income, max ~EUR 5,100/quarter | Capped, effectively much lower |
| Securities account tax | 0.15% above EUR 1M (proposal: 0.30%) | None |
| Inheritance tax (children) | 3% - 30% (regional) | 0% for close relatives |
| VAT (standard) | 21% | 20% |
| Currency | EUR | EUR (since Jan 2026) |
Concrete example: A Belgian SRL owner with EUR 150,000 of company profit pays roughly EUR 37,500 in corporate tax (25%) and then, on dividend distribution, approximately 30% withholding on the EUR 112,500 net (or 15% under strict VVPRbis conditions). Total tax burden: roughly EUR 71,000 without VVPRbis, or EUR 54,400 with VVPRbis — effective rates of 47% and 36% respectively. The same EUR 150,000 through a Bulgarian EOOD: EUR 15,000 CIT + EUR 6,750 dividend tax = EUR 21,750 total. Annual saving of roughly EUR 32,000 to EUR 49,000.
Belgium-Bulgaria Double Tax Treaty
Belgium and Bulgaria are bound by a double tax convention signed in 1988 and in force since the early 1990s — one of the older EU-Bulgaria treaties, now modernised through the OECD Multilateral Instrument (MLI) which layers beneficial-owner and anti-abuse tests over the original text. The full treaty architecture can be consulted via EUR-Lex and the Belgian tax administration at financien.belgium.be.
Key principles
- Residence tie-breaker: permanent home → centre of vital interests → habitual abode → nationality → mutual agreement. Once you settle in Bulgaria with your family and economic activity, you become a Bulgarian resident under the treaty.
- Elimination of double taxation: credit method. Bulgaria, as residence state, taxes your worldwide income at 10% (personal) or 10% + 5% (corporate chain) and credits any Belgian tax withheld under treaty caps.
- Business profits: taxable only in the state of residence unless a permanent establishment (PE) exists in the other state.
- Employment income: taxed where the work is physically performed, with a 183-day rule for short-term assignments.
- Rental income from Belgian real estate: Belgium retains the right to tax cadastral/rental income from property situated in Belgium.
- Pensions: private pensions (including statutory old-age) generally taxable in the state of residence; government pensions remain taxable in Belgium.
Practical note: The 1988 treaty predates several modern OECD concepts. For dividends, interest, and royalties, confirm the exact treaty-capped rate and any applicable MLI principal-purpose test with your tax advisor — do not rely on generic treaty tables that may not reflect MLI overlays. Once you are resident in Bulgaria, the NRA (Bulgarian revenue agency) can issue a tax residency certificate that you use to invoke the treaty against Belgian withholding.
Belgian Wealth Tax on Securities Accounts
Belgium does not have a classical net wealth tax. But since 2021 it levies an annual tax on securities accounts (taxe annuelle sur les comptes-titres / jaarlijkse taks op de effectenrekeningen).
Current rules
- Rate: 0.15% per year.
- Threshold: securities accounts with an average value exceeding EUR 1 million.
- Measurement: the average is assessed four times per year — on 31 December, 31 March, 30 June, 30 September.
- Withheld by the bank: your Belgian financial intermediary (KBC, BNP Paribas Fortis, Belfius, ING, Keytrade) calculates, withholds, and remits the tax automatically.
- Anti-abuse: splitting your account across multiple institutions, converting into registered securities, or transferring assets to drop below EUR 1 million is presumed abusive. Banks must report suspicious operations to the Belgian tax administration.
2026 budget proposal
The 2026-2029 federal budget framework floats a doubling of the rate to 0.30%, not yet final as of publication. High-net-worth Belgian residents with discretionary portfolios above EUR 1 million face a meaningful cost.
Impact when you move to Bulgaria
Once you cease to be a Belgian tax resident and your securities account is transferred to a Bulgarian or other non-Belgian broker, the annual tax no longer applies. Bulgaria has no equivalent wealth tax or securities tax. Capital gains on shares listed on EU/EEA regulated markets (including Euronext Brussels and most EU exchanges) are exempt from Bulgarian personal income tax for individuals — a substantial benefit for active investors.
Belgian Property After Leaving
If you keep a house or apartment in Belgium, your tax exposure shifts but does not disappear:
- Non-resident income tax (IPP-NR / BNI-PP): you continue to declare Belgian-source income — primarily the deemed cadastral income (revenu cadastral / kadastraal inkomen) on owner-used property, or actual rental income on let property — on a non-resident return.
- Cadastral income reform: Belgium now taxes actual rents received from Belgian real estate (not only indexed cadastral income), following the 2020 ECJ ruling on discrimination against foreign property owners.
- Property tax (précompte immobilier / onroerende voorheffing): continues to apply regardless of your residence, levied by the region (Flanders, Wallonia, Brussels).
- Rental income flow: collected in Belgium, taxable in Belgium under the treaty, then reported in Bulgaria with a credit for Belgian tax paid.
- Sale of Belgian property: Belgian capital gains rules on real estate apply — typically a flat 16.5% on sales within 5 years, 33% for certain speculative cases, exempt for long-held principal residences.
Belgian Pensions & Social Security
Your Belgian pension rights survive the move. EU Regulation 883/2004 on social security coordination protects you.
Statutory old-age pension
- The Belgian Federal Pensions Service (Service fédéral des Pensions / Federale Pensioendienst) pays your statutory pension into a Bulgarian EUR bank account from day one of retirement age.
- Years worked in Belgium count toward your entitlement regardless of your later residence.
- Under the BE-BG treaty, private pensions (including statutory old-age for employees and self-employed) are generally taxable in the residence state — Bulgaria, at 10%.
- Civil-service (government) pensions remain taxable in Belgium.
Second-pillar pensions
Occupational pensions accumulated in Belgian employer plans (assurance-groupe / groepsverzekering) are portable. The treatment of lump-sum versus annuity payouts depends on the timing of accrual and current Belgian payout rules — for large accrued capital, coordinate with a Belgian pension specialist before triggering distribution from Bulgaria.
Self-employed social security
If you were self-employed in Belgium, you contributed through a social insurance fund (Securex, Xerius, Liantis, Partena) at approximately 20.5% of net professional income, capped at around EUR 5,100/quarter in 2026. You must notify your fund of your departure. Your Bulgarian replacement: social contributions as a manager/owner of a Bulgarian EOOD, with capped bases that in practice cost a fraction of the Belgian figure.
Timeline: From Decision to Operating
A realistic Belgium-to-Bulgaria relocation, assuming no complications:
- Month -3 to -2 (pre-departure planning): engage a Belgian fiscaliste to model the exit tax and the new capital gains rules. Get a valuation of any Belgian/foreign company shares. Decide whether to sell before or after departure.
- Month -2 to -1: register a Bulgarian EOOD remotely (or on a scouting trip). Minimum capital EUR 1. Open a corporate bank account or start the process. Line up Bulgarian address (rental or service address).
- Month -1: notify mutualité, social insurance fund, Belgian tax office, and any professional regulators. Close or convert securities account if over EUR 1 million.
- Departure week: visit commune for model 8. Hand in identity card. Receive certificate. Leave.
- Week 1 in Bulgaria: register rental contract, submit EU residence application at Migration Directorate, obtain LNCH.
- Week 2-4: register with NRA as Bulgarian tax resident; finalise NHIF coverage through EOOD contributions; activate Bulgarian bank cards.
- Month 2-3: first payroll/dividends through Bulgarian EOOD; Bulgarian accountant starts monthly filings; VAT registration if turnover warrants.
- Following year: file final Belgian non-resident return for any Belgian-source income; file first full Bulgarian annual return; obtain NRA tax residency certificate for treaty purposes.
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Book Free Consultation →Common Mistakes Belgian Relocators Make
1. Keeping Belgian domicile "just in case"
Some Belgians leave their family registered at the parents' address in Belgium "for administrative convenience". This is the single most expensive mistake. FPS Finance will argue you never left. Your Bulgarian residency will be challenged under the treaty tie-breaker. You end up paying Belgian top rates on your worldwide income. Deregister fully. Move your family. Shift your centre of vital interests.
2. Ignoring the new 2025 exit tax
Because Belgium had no exit tax until July 2025, many Belgian advisors are still catching up. Do not assume older guides or forum posts apply. The new rules cover latent capital gains on financial assets if disposed of within 24 months of departure, and a deemed dividend on corporate emigration. Confirm with a Belgian tax advisor — rules changed 2024-2025.
3. Not filing the special return for the year of departure
For the fiscal year in which you leave, you must file a special (split-year) return covering the period you were a Belgian resident. Missing this return is treated as a late filing and generates penalties and interest.
4. Forgetting the securities account tax "exit"
If your Belgian securities account crosses EUR 1 million on any of the four reference dates (31 December, 31 March, 30 June, 30 September), you owe the tax even if you leave mid-year. Plan your account transfer around these dates.
5. Registering at a police station in Bulgaria
Outdated guides still refer to "local police registration" or "GRAO" for EU citizens. This is incorrect. The Migration Directorate is the only authority. Going to the wrong office wastes days. See our address registration guide for foreigners and the detailed EU residence permit walkthrough.
6. Not spending 183 days in Bulgaria in year one
If you move in October, the calendar-year Bulgarian day count is mathematically insufficient to claim tax residency for that year — unless you can prove centre of vital interests, which is difficult for newcomers. For a clean treaty-compliant break, plan your move for January to March.
Common questions before booking:
Is this legal? Yes. EU freedom of movement is a treaty right. Bulgaria's 10% flat tax is set by national law.
Do I need to speak Bulgarian? No. We handle everything in English (and French or Dutch on request).
What does it cost? Full relocation packages from EUR 2,000. First consultation is free.
How fast? Residence card in 1-14 days. Full setup in 2-4 weeks. Clean tax break from the following Belgian tax year.
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Frequently Asked Questions
Do I need to deregister from my commune before moving to Bulgaria?
What is the new Belgian exit tax that started in 2025?
What is the tax rate in Bulgaria compared to Belgium?
How does the Belgium-Bulgaria double tax treaty work?
Will I still receive my Belgian pension in Bulgaria?
What happens to my Belgian securities account tax?
Can I keep my Belgian property if I move to Bulgaria?
Do I need a visa or residence permit as a Belgian citizen?
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Book Free Consultation →Disclaimer: This article provides general information about relocating from Belgium to Bulgaria and does not constitute legal or tax advice. Belgian tax rules changed materially in 2024 and 2025 (Arizona coalition program law, new individual exit tax, new capital gains tax from 1 January 2026) and interpretation is still evolving. Belgian tax matters must be coordinated with a Belgian fiscaliste/belastingadviseur. Consult our team for advice tailored to your specific situation. Last updated: April 11, 2026.