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Payroll exemption Active

Partial withholding tax exemption for R&D personnel

Employers of qualifying researchers may retain 80% of the professional withholding tax on their salaries instead of remitting it — an immediate, rule-based reduction of R&D labor cost of roughly 15–20%.

3 Jul 2026

Key parameters

Exemption rate 80% of the professional withholding tax remittance
Eligible degrees Doctoral/master degrees (full rate); bachelor degrees eligible but capped Bachelor reduction limited to max 25% of the reduction applied to master/doctoral staff
Qualifying fields Applied/exact sciences, engineering, medical & veterinary science
Preliminary condition Project/programme notified to BELSPO before start (mandatory)

Eligibility

HQ
Any headquarters country
Local presence
Local tax presence required (branch is sufficient) A branch office (Zweigniederlassung/permanent establishment) of your existing company is enough — you do not need to form a new legal entity such as a GmbH or BV.
R&D substance
Required
Company size
No size restriction
Models
All
Sectors
All
Goals
Additional design site in Europe; R&D cooperation without own site

R&D projects/programs must be notified to BELSPO before they start — the Belgian courts have confirmed this preliminary notification is an essential (substantive) condition. Both the diploma and the actual R&D involvement of each researcher must be documented.

Mechanism & application

Rule-based entitlement — Legal entitlement — self-assessment, no case-by-case funding decision.

Notify the R&D projects/programs to BELSPO before start; apply the exemption directly in periodic payroll withholding tax returns and keep per-researcher documentation.

Timeline: Immediate via payroll once BELSPO notification is in place

Legal basis & sources

Legal basis
Art. 275/3 CIR 92
Source
https://www.belspo.be/belspo/fisc/index_en.stm
Verification
CIR 92 Art. 275/3 / BELSPO (2026 rate 80%; bachelor cap 25%)
from 1 Jan 2006 until no expiry review 1 Jan 2027

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