Leaving Belgium for Dubai: the exit tax that did not exist last year

For years the standard line on Belgium was comfortable: high taxes on income, almost none on capital, and no exit tax when you leave. Half of that is now wrong.

Since 1 January 2026, moving your tax residence out of Belgium is itself a taxable event. The rule is new enough that most guides still repeat the old position, and old enough that the first deadlines are already running.

What actually changed

The instrument is the law of 6 April 2026 introducing a tax on capital gains on financial assets, published in the Belgisch Staatsblad on 21 April 2026 and in force since 1 January 2026.

Article 4 of that law inserts a new article 92 into the WIB 92. Its paragraph 2 places on the same footing as a disposal for consideration the “overbrengen van de woonplaats of zetel van fortuin buiten België”, the transfer of your residence or of the seat of your assets abroad. The notional gain arising on that date is taxed.

So this is not a residual anti-abuse rule. Emigration is written into the statute as the trigger.

The rates

The law sorts financial assets into three categories under the new article 90 paragraph 1 number 9:

Category	What it covers
a	transfers of shares to an acquirer controlled by the transferor alone or with family, so internal capital gains
b	shares where the transferor holds at least 20 percent of the rights in the company
c	all other financial assets

Category c is taxed at a flat 10 percent. The annual allowance has a base amount of 4,855 euro, indexed to 10,000 euro for tax year 2027. A transferable portion, base amount 480 euro and indexed to 1,000 euro, can be accumulated over five years up to a maximum of 15,000 euro.

Category b, the substantial holding, is the one that matters for founders, and it is graduated:

Tranche	Rate
up to 1,000,000 euro	0 percent
1,000,000 to 2,500,000 euro	1.25 percent
2,500,000 to 5,000,000 euro	2.5 percent
5,000,000 to 10,000,000 euro	5 percent
above 10,000,000 euro	10 percent

Pension savings accounts, group insurance and long-term savings contracts are expressly exempt from the new tax. For an ordinary employee that carve-out covers most of what they have.

The Dubai problem: security, because the treaty is missing an article

Article 31 of the law inserts a paragraph 6 into article 413/1 WIB 92, governing deferral of payment on emigration. Deferral is granted where residence moves to an EU state, an EEA state, or a state with which Belgium has concluded a double tax treaty providing for exchange of information and mutual assistance in recovery.

The Belgium and UAE treaty, signed in Washington on 30 September 1996 and in force since 6 January 2004, contains article 26 on exchange of information and no article on recovery assistance at all. The article sequence ends with non-discrimination, mutual agreement, exchange of information, diplomats, entry into force and termination. There is nothing in between for recovery.

The administration states the consequence without softening it: if you move to another country, you must request the deferral and provide sufficient security for payment of the tax.

That is the practical cost of moving to Dubai rather than to Amsterdam. Not a different rate. A pledge or guarantee sitting idle for two years.

The 24 month rule, which is the good news

The deferral lapses in three cases: the financial assets are disposed of for consideration, the taxpayer takes up residence in Belgium again within 24 months, or 24 months simply pass.

The administration’s own summary: the tax is not due if you do not sell your financial assets in the two years following your departure.

Read that carefully. The exit tax is not a bill you pay, it is a bill you avoid by sitting still for two years. For someone moving to Dubai to build something rather than to cash out immediately, that changes the whole calculation.

It is conditional on paperwork, and the paperwork has hard dates:

Requirement	Deadline after departure
First certificate	at the latest 14 months
Second certificate	at the latest 26 months
Special return for the year of departure	in principle 3 months

Without a certificate filed on time, the tax falls due. The special return covers both realised and notional gains, and departures before 1 May 2026 are exempt from declaring the gains. The calculation detail sits in circular 2026/C/74 of 22 July 2026.

Leaving properly

Residence under article 2 paragraph 1 number 1 of the CIR 92 turns on your domicile, or failing that the siège de la fortune, the centre of your economic activities or asset interests. Both are judged on the facts, and registration in the Rijksregister creates a rebuttable presumption of residence, not a conclusive one. For married and legally cohabiting couples the tax residence is where the household is established, and both partners fall together into either resident or non-resident taxation.

Any Belgian intending to take up habitual residence abroad must notify the municipal authority of their place of residence at the latest on the day before departure. The municipality then issues a certificate of removal from the population registers, and the Belgian administration is explicit that the tax position changes as soon as that removal happens.

Registration with the consulate afterwards is not compulsory but recommended. Without it there is no identity card, no consular certificate of residence or nationality, no passport service and no participation in federal elections.

What carries on after you have gone

• No social security agreement exists with the Emirates. The official leaving Belgium portal lists the EEA, Switzerland, the United Kingdom and around two dozen treaty states, and the UAE is not among them. The route for Belgians outside the EEA is the Overzeese Sociale Zekerheid, whose basic package reimburses medical costs only from a certain age and after at least 16 years of contributions, with immediate cover available as a supplementary insurance.
• The 3.55 percent health insurance deduction on your pension stays, as does the solidarity contribution. Exemption from either requires residence in the EEA, the United Kingdom or Switzerland.
• The pension is paid worldwide, but notify the move two months before departure, in writing and signed, because telephone and email are not accepted. A life certificate must be returned within 30 days and legalised by a municipality, your own embassy or consulate, or the police. A bank, a doctor, a lawyer or a pharmacist will not do.
• Family allowances end. In Flanders the Groeipakket requires the child to be resident, there is no agreement with the Emirates, and the general exemption fails anyway once a parent works in the country where the children live.
• A Flemish property keeps costing. The onroerende voorheffing has a base rate of 3.97 percent on the indexed kadastraal inkomen, with an indexation coefficient of 2.3000 for tax year 2026, plus provincial and municipal surcharges set locally. On a later sale as a non-resident the gain is generally untaxed outside a professional activity, but 30.28 percent applies where the transaction falls outside normal management of private assets, and 33 or 16.5 percent applies to land sold within 8 years and buildings within 5 years of purchase.
• A Belgian securities account catches you as a non-resident. The annual tax applies where the average value of taxable financial instruments exceeds 1,000,000 euro, at 0.15 percent for reference periods ending by 31 May 2026 and 0.30 percent for those ending from 1 June 2026, and its territorial scope expressly includes non-residents holding an account with a Belgian intermediary.

What this means in practice

1. Fix the date of departure first. Everything else counts from it: three months to the special return, fourteen and twenty-six months to the certificates, twenty-four months to the point where the tax disappears.
2. Decide whether you are selling within two years. If you are not, the exit tax is a security requirement and a diary entry rather than a payment.
3. Arrange the security while you are still in Belgium. The deferral is not automatic here, it is requested, and it requires a guarantee the administration accepts.
4. Separate your pension pots from your portfolio. Pension savings, group insurance and long-term savings contracts are outside the tax, and treating them as ordinary investments before leaving is an expensive mistake.
5. Deregister at the municipality by the day before you go, and keep the certificate of removal.

The Dubai side is the simple half. A company, a residence visa, an Emirates ID, a corporate tax registration, with published fees and fixed deadlines, and you can work the first year out yourself in our company cost calculator.

The expensive half is the country you are leaving, and Belgium moved into a different category this year. Britain, by comparison, still has no exit tax at all and reaches you through inheritance tax instead.

We handle the UAE side, the accounting, the tax registrations and the deadlines. The Belgian side belongs with a Belgian adviser who has already worked with the April 2026 law, and it belongs there before the move, not after it.

This article is part of a series comparing what leaving costs across fifteen countries. The overview, with a table of every exit charge and how long each tail runs, is in what leaving costs, by country.