How are German accumulating ETFs and a Bausparvertrag taxed in Belgium for income year 2026?
How are German ETFs and a Bausparvertrag taxed in Belgium? Learn the reporting, TOB, Reynders tax, capital-gains rules and how to correct past years.
For income year 2026, assessment year 2027, a Belgian tax resident must report German bank, securities and savings accounts in Belgium, may owe Belgian stock exchange tax on transactions through a foreign institution, and may be taxed on Bauspar interest and ETF gains when units are sold. Accumulating ETFs are generally not taxed annually in Belgium merely because income is reinvested, but the correct treatment depends on the funds, transactions and individual situation.
The figures below are illustrative. The framework mainly concerns income year 2026, assessment year 2027, while historical corrections may relate to earlier income years that remain open for assessment.
Belgian residence and the Belgium–Germany tax framework
A Belgian tax resident is generally taxable in Belgium on worldwide income, including income and gains connected with accounts and investments held in Germany.
Under the Belgium–Germany double tax treaty, income and capital gains from fund units held by a Belgian resident are generally taxable in Belgium as the state of residence.
Germany may retain limited taxing rights in specific situations, particularly for dividends from direct holdings in German companies. However, German taxation of fund accumulation or fund gains may not be justified once the investor is no longer a German tax resident.
This creates two separate questions:
What must be reported and taxed in Belgium?
Was any German tax correctly withheld, or should it be reclaimed in Germany?
Which German accounts must be reported in Belgium?
Belgian residents must normally report foreign accounts at two levels.
First, each foreign account must be notified once to the Central Point of Contact, or CPC/PCC, of the National Bank of Belgium.
Second, the existence of those accounts must be mentioned annually in box XIII, section A of the Belgian personal income tax return.
The obligation is not limited to ordinary current or savings accounts. It also covers:
foreign securities accounts;
accounts containing shares, bonds or investment funds;
certain savings contracts held with foreign financial institutions;
accounts over which the taxpayer, a spouse or dependent children have control.
A securities account containing German ETFs must therefore normally be reported separately, even when ordinary German bank accounts have already been declared.
A Bausparvertrag may also fall within the foreign-account reporting obligation. Whether it has already been correctly covered depends on how the account was identified in the earlier CPC notification and tax returns.
Belgium receives information about foreign financial accounts automatically under international exchange-of-information systems such as CRS/DAC. A taxpayer should therefore not assume that an unreported securities account is unknown to the Belgian administration.
Is Belgian stock exchange tax due when using a German bank?
Purchases and sales of securities by a Belgian resident may be subject to the Belgian tax on stock exchange transactions, commonly called TOB.
When transactions are executed through a Belgian bank, the bank normally calculates, withholds and pays the TOB.
When a Belgian resident uses a foreign bank or broker that does not handle Belgian TOB, the investor generally becomes responsible for declaring and paying the tax.
The deadline is normally the last working day of the second month following the transaction.
Depending on the security and its registration status, the applicable rate may be:
0.12%;
0.35%; or
1.32%.
Maximum amounts apply per transaction.
The correct rate for an ETF depends on factors such as:
whether the fund is registered in Belgium or another relevant jurisdiction;
whether it is distributing or accumulating;
the legal form of the fund;
the precise transaction performed.
Accumulating ETFs can fall within the higher TOB rate in certain circumstances. The correct rate should therefore be verified using the fund’s ISIN, prospectus and registration information.
TOB is separate from personal income tax. A person may have no annual taxable ETF income but may still owe TOB on purchases and sales.
Are accumulating ETFs taxed every year in Belgium?
No Belgian equivalent of the German Vorabpauschale
Belgium does not generally impose annual personal income tax simply because income is accumulated inside an investment fund.
An accumulating ETF reinvests its income instead of distributing it to the investor. If no distribution or sale occurs, the investor will generally have no annual Belgian movable income to declare solely because the ETF increased in value.
Belgium therefore has no direct equivalent of the German Vorabpauschale for an ordinary private investor.
For historical years in which the investor merely held accumulating ETFs without selling them, the main Belgian compliance issues may therefore be:
failure to report the securities account;
unpaid TOB on purchases;
other foreign income credited outside the ETF, such as interest on a savings contract.
The mere internal accumulation within the ETF does not generally create annual Belgian taxable income.
Does the annual securities-account tax apply?
Belgium imposes an annual 0.15% tax on securities accounts where the average value of the account reaches at least €1,000,000.
An account whose average taxable value remains below that threshold is normally outside the scope of this tax.
The threshold applies to the securities account rather than simply to one ETF position. Anti-abuse rules may also be relevant where accounts are artificially divided to avoid the threshold.
What happens when a mixed ETF is sold?
Two Belgian tax regimes may be relevant when ETF units are sold from income year 2026 onward.
The Reynders tax on the bond component
Under article 19bis CIR 92, the interest-related component of a gain on certain funds may be taxable at 30%.
This regime generally applies when the fund invests more than 10% of its assets in debt instruments. It may therefore affect many mixed ETFs and bond funds.
A pure equity ETF whose exposure to debt instruments remains below the relevant threshold may fall outside the Reynders-tax regime.
The taxable amount is normally determined using the Belgian taxable income per share, or TIS, published for the fund.
Where no appropriate Belgian TIS is available, the calculation may instead depend on the realised gain and the fund’s bond proportion.
With a Belgian financial institution, the tax may be withheld automatically. With a German bank or foreign broker, no Belgian withholding may occur. The Belgian resident may then have to declare the taxable amount personally, including where applicable under code 1444 of box VII.
Identifying the exact funds is therefore essential. Relevant documents include:
ISIN codes;
key information documents;
prospectuses;
annual fund reports;
information about the proportion invested in bonds;
any available TIS data.
The 10% capital-gains tax from 2026
According to the framework applicable from 1 January 2026, Belgium levies a 10% tax on realised capital gains on financial assets, whether the assets are Belgian or foreign.
For assets acquired before 1 January 2026, gains accumulated before 2026 are protected through a reference value at 31 December 2025.
The acquisition value used for future calculations is generally the value on 31 December 2025. Where the actual historical acquisition price was higher, the taxpayer may invoke that higher price.
This makes the year-end valuation particularly important. Investors holding foreign investments should retain official evidence showing the value of each position on 31 December 2025, such as:
the year-end securities statement;
the number of units held;
the market value per unit;
the applicable currency conversion;
transaction records showing the original acquisition price.
Each taxpayer also benefits from an annual exemption of €10,000 of realised gains, subject to indexation and the applicable carry-forward rules.
Because a German bank will generally not withhold Belgian capital-gains tax, the Belgian resident must normally calculate and report the taxable gain through the Belgian tax return.
How do the Reynders tax and the 10% tax interact?
The same gain should not be taxed twice on the same component.
Where a fund falls within article 19bis:
the interest or bond component is taxed at 30% under the Reynders-tax regime;
only the remaining part of the relevant post-2025 gain is considered for the 10% capital-gains tax.
The precise calculation depends on the fund data, sale price, reference value at 31 December 2025, available TIS and annual exemption.
Illustrative calculation
Assume an investor sells ETF units and realises a total economic gain of approximately €40,000.
Suppose:
around €10,000 of the gain accrued before 31 December 2025;
approximately €5,000 represents the taxable bond component under the TIS;
the remaining relevant post-2025 non-bond gain is around €25,000.
The indicative calculation could be:
Reynders tax: 30% of €5,000 = €1,500;
capital-gains tax: annual exemption of €10,000 applied to the €25,000 remainder;
taxable remainder: €15,000;
capital-gains tax: 10% of €15,000 = €1,500.
The combined tax would be approximately €3,000.
This is only an illustration. The actual calculation can change materially depending on the acquisition price, 31 December 2025 valuation, TIS, bond proportion, losses, exemption and timing of the sale.
Spreading sales over different tax years may allow the annual exemption to be used more than once, but the wider investment and tax consequences should be reviewed before transactions are reorganised.
What if German tax was already withheld?
German banks may impose tax connected with the Vorabpauschale or with investment income when their records still classify the investor as a German tax resident.
The Vorabpauschale is intended as an advance taxation mechanism for investors who are subject to German taxation. It should generally cease once the investor is no longer subject to unlimited German tax liability.
If a Belgian resident continues to suffer German withholding on accumulating fund holdings, the first step is to verify the residence status recorded by the German bank.
The bank may request:
proof of Belgian address;
a Belgian tax-residence certificate;
updated tax-identification information;
confirmation of the date on which German residence ended.
Past German tax that was not due under German law or the treaty normally has to be reclaimed in Germany, either through the bank or the competent German tax authority.
Belgium will not necessarily grant a tax credit for German tax that was incorrectly withheld. Where the treaty allocates the taxing right to Belgium, recovery in Germany may be the only way to avoid definitive double taxation.
Annual German Steuerbescheinigungen should be obtained for all relevant years to identify:
the type of tax withheld;
the taxable base used;
the date of withholding;
the amount of Kapitalertragsteuer;
any solidarity surcharge or related amount;
whether the withholding concerned a distribution, sale or Vorabpauschale.
German refund claims are subject to time limits. They should therefore be examined without unnecessary delay.
How is a Bausparvertrag taxed in Belgium?
A Bausparvertrag combines a savings component with the possibility of a future housing loan. German subsidies may also be attached to the contract.
For Belgian purposes, three issues should be distinguished.
Interest credited to the contract
Interest credited annually to a Bausparvertrag is generally movable income.
Where no Belgian withholding tax has been deducted, the Belgian resident may have to declare that interest personally. The standard Belgian movable-income tax rate mentioned in the analysis is 30%.
The Belgian exemption for regulated savings deposits can extend to comparable accounts in the European Economic Area only where strict conditions are satisfied.
A Bausparvertrag will not automatically qualify for this exemption. Its legal and contractual characteristics must be compared with the Belgian requirements.
German housing subsidies
German state support may include measures such as:
the Wohnungsbauprämie;
the Arbeitnehmersparzulage.
These subsidies may be conditional on:
the date on which the contract was entered into;
a minimum holding period;
the use of the funds for a qualifying housing purpose;
the investor’s income;
other German statutory conditions.
Terminating the contract or withdrawing the funds without a qualifying housing purpose may cause subsidies to be lost or repaid.
The Bausparkasse should therefore confirm the consequences before the contract is terminated.
Belgian treatment when the contract is liquidated
The repayment of the investor’s own savings is generally a non-taxable repayment of capital.
Interest remains subject to the applicable movable-income rules.
The Belgian treatment of German state premiums depends on their precise legal nature. They may need to be analysed separately rather than automatically being treated as ordinary savings interest.
How can earlier omissions be corrected?
A file involving a foreign securities account may contain several distinct omissions:
the securities account was not notified to the CPC;
the account was omitted from box XIII;
TOB was not declared on purchases or sales;
Bauspar interest was not declared;
Belgian tax was not declared when ETF units were sold;
German tax was withheld even though the investor was Belgian-resident.
These issues should not be treated as one single tax debt. Each has its own correction procedure, deadlines and possible penalties.
Route 1: spontaneous corrective declarations
For income years that remain open, taxpayers may approach the competent tax office and submit corrections spontaneously.
Depending on the omission, the administration may impose:
the underlying tax;
late-payment interest;
an administrative fine;
a tax increase.
For a first infringement without fraudulent intent, the analysis refers to a tax increase that is typically 10%, although it may be waived in genuine good-faith circumstances.
Late TOB must be corrected through the appropriate TOB declarations and payment process, including where applicable through MyMinfin.
A spontaneous correction may be proportionate where:
the capital came from taxed salary or other documented sources;
ordinary foreign bank accounts were already declared;
there was no concealment structure;
the main taxable omission concerns limited interest income;
account-reporting and TOB errors resulted from misunderstanding rather than fraud.
Route 2: permanent regularisation under DLU quinquies
The permanent regularisation procedure known as DLU quinquies was introduced under the Programme Law of 18 July 2025.
Under the framework described in the analysis:
non-time-barred undeclared income is taxed at the normal rate plus 30 percentage points;
fiscally time-barred capital may be subject to a 45% levy;
the procedure may provide tax and criminal immunity within its applicable scope.
This route can be significantly more expensive than ordinary corrective declarations.
It is particularly relevant where:
the normal tax treatment of the capital cannot be demonstrated;
the origin of the funds is insufficiently documented;
time-barred capital is involved;
broader criminal-tax protection is required.
Where the investments were funded entirely from documented, previously taxed income, the need for a 45% levy on the capital itself may be avoided. However, the choice between an ordinary correction and DLU quinquies should be made only after reviewing the documents and procedural status.
Assessment periods and foreign account information
The ordinary Belgian assessment period is generally three years, with an extension to four years in certain situations.
Longer assessment periods may apply where fraudulent intent is established.
The analysis also notes that the extended six- and ten-year periods introduced in 2022 for certain complex returns were abolished by the Law of 18 December 2025, retroactively from assessment year 2023.
Separate assessment possibilities may arise when the Belgian administration receives information from foreign authorities.
The practical exposure therefore depends on:
the income year concerned;
whether a return was filed;
the nature of the omission;
whether the administration considers the omission fraudulent;
when Belgium received foreign-account data;
whether an audit or formal investigation has already started.
Why acting spontaneously matters
Timing can influence both the available correction route and the penalties.
A regularisation must normally be initiated before an audit or judicial procedure prevents it from being considered spontaneous.
Even outside DLU quinquies, voluntarily contacting the administration may support the argument that the omission resulted from good faith rather than an intention to conceal taxable assets or income.
Receiving a general notification that Belgium has obtained foreign-account information does not necessarily mean that every correction route is already closed. However, the precise status of the file must be checked immediately.
Practical compliance checklist
A Belgian resident holding German investments should consider the following steps.
Identify every German account
List current accounts, savings accounts, securities accounts and Bauspar contracts.
Check the CPC registrations
Confirm that every reportable account has been notified correctly to the National Bank’s Central Point of Contact.
Review box XIII
Verify that all foreign accounts have been mentioned in each relevant annual Belgian return.
Collect the ETF documentation
Obtain the ISIN, prospectus, KIID, bond allocation and available TIS for every fund.
Preserve 31 December 2025 values
Keep official evidence of the year-end value and number of units for every position held before 2026.
Reconstruct transactions
Prepare a list of every purchase and sale made through the German institution, including dates, values and applicable TOB rates.
Obtain German tax certificates
Request the Steuerbescheinigungen for every relevant year and determine why German tax was withheld.
Review the Bausparvertrag
Separate capital contributions, annual interest and German state premiums.
Check the origin of the invested capital
Retain salary statements, bank transfers, inheritance documents or other evidence showing that the capital originated from taxed or exempt funds.
Choose the appropriate correction route
Compare ordinary spontaneous corrections with DLU quinquies before filing.
Frequently asked questions
Do I have to declare a German securities account if I already declared my German bank account?
Yes. A securities account is itself a reportable foreign account and may require a separate CPC notification and annual mention in box XIII.
Are accumulating ETFs taxed every year in Belgium?
Generally, no. Belgium does not normally tax the internal annual accumulation of an ETF when no distribution or sale occurs, although account reporting and TOB obligations may still apply.
Do I owe TOB when my German bank does not charge it?
Potentially, yes. A Belgian resident using a foreign institution may have to calculate, declare and pay Belgian TOB personally by the applicable deadline.
Is the whole gain on a mixed ETF taxed at 30%?
Not necessarily. Under the Reynders-tax regime, the 30% rate generally applies to the interest or bond component determined under article 19bis, rather than automatically to the entire economic gain.
Can German Vorabpauschale tax simply be deducted from Belgian tax?
Not generally. If Germany had no taxing right, the amount usually needs to be reclaimed in Germany rather than credited in Belgium.
Is DLU quinquies always required for an undeclared foreign investment account?
No. A spontaneous ordinary correction may be sufficient where the source of the capital is documented and the omission does not involve fraud or unexplained time-barred capital. The procedural position must nevertheless be reviewed before choosing a route.
Sources
FPS Finance — Accounts abroad (CPC and box XIII) — https://fin.belgium.be/en/private-individuals/international/foreign-income-accounts/accounts
National Bank of Belgium — Central Point of Contact: reporting foreign accounts — https://www.nbb.be/en/central-credit-registers/central-point-contact-accounts-and-financial-contracts-cpc-5
FPS Finance — Circular 2026/C/42, FAQ on the tax on stock exchange transactions — https://blog.oeccbb.be/fr/article/circulaire-2026c42-faq-tob-taxe-sur-les-operations-de-bourse-version-2/30750
FPS Finance — Tax on stock exchange transactions: declaration and payment — https://fin.belgium.be/fr/particuliers/international/revenus-comptes-etrangers/taxe-operations-bourse
Test-Achats Invest — Reynders tax with a foreign broker: how to declare — https://www.test-achats.be/invest/investir/fiscalite-et-droits/articles/2026/07/taxe-reynders-courtier-etranger
FPS Finance — The capital gains tax — https://fin.belgium.be/fr/particuliers/declaration-impot/revenus/taxe-plus-values
Beobank — The new capital gains tax from 2026 — https://www.beobank.be/fr/blog/mon-patrimoine/nouvelle-taxe-sur-les-plus-values-2026.html
Triodos Bank — What happens to the Reynders tax? — https://www.triodos.be/fr/questions-les-plus-frequentes/quadvientil-de-la-taxe-reynders
Prof. Dr. Hartmut Walz — Vorabpauschale and moving abroad — https://hartmutwalz.de/vorabpauschale/
FPS Finance, Ruling Office — Permanent regularisation procedure, DLU quinquies — https://www.ruling.be/fr/telechargements/procedure-permanente-de-regularisation-dlu-quinquies
Tiberghien — DLU quinquies: revolution or status quo? — https://www.tiberghien.com/fr/4361/dluquinquies-une-revolution-ou-un-statut-quo
Degand & Partners — Tax assessment periods 2026 — https://blog.degandpartners.com/fr/article/delais-fiscaux-2026-une-complexite-ajusteevraiment-/30806
This article presents a general framework and does not constitute a personalised tax opinion. Tax rules may change from one income or assessment year to another, and the correct treatment depends on the exact accounts, investments, transactions, residence history and documentation.
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