A Belgian tax resident who receives a lump-sum payment from a Maltese pension arrangement during 2026 should normally deal with it in the Belgian personal income tax return for income year 2026, assessment year 2027. Belgium is expected to have the taxing right under the Belgium–Malta treaty, but the Belgian tax treatment depends on whether the payment is taxable pension income, separately taxable pension capital, or partly a non-taxable return of after-tax contributions. The correct answer depends on the taxpayer’s individual situation and supporting documents.

The figures below are illustrative and relate to income year 2026 / assessment year 2027, using a rounded foreign pension lump sum of about €89,000.

Why the lump sum belongs in the 2026 Belgian tax return

When a Belgian tax resident receives a foreign pension lump sum during 2026, that amount belongs to the 2026 income year. In Belgium, that corresponds to assessment year 2027.

This means there is normally no separate Belgian tax return to file immediately when the pension is paid. The amount should instead be handled in the ordinary Belgian personal income tax return filed in 2027.

The exact filing deadlines for income year 2026 were not yet available in the source analysis. As a reference, for the current Belgian filing season mentioned in the analysis, the tax administration provided deadlines of 30 June for paper returns, 15 July via MyMinfin, and a later October deadline for certain specific income situations. The exact 2027 deadline should therefore be checked when the assessment year 2027 return becomes available.

If the taxpayer receives a simplified tax proposal and the foreign pension lump sum is not included, it should not simply be accepted without review. Foreign pensions are not always pre-filled, and Belgian residents are generally expected to declare their worldwide income, including foreign pensions.

Which country may tax a Maltese pension lump sum?

Under the Belgium–Malta double tax treaty, pensions and similar remuneration paid to a resident of one state in consideration of past employment are generally taxable only in the state of residence.

For a Belgian tax resident, this points to Belgium.

Even if the payment were analysed not as an employment pension but as another type of income from a private pension arrangement, the treaty’s residual rule would also generally point to taxation in the state of residence. In practical terms, where the taxpayer is Belgian resident at the time of payment, Belgium is expected to be the country with the taxing right.

This also means that, if no Maltese tax was withheld, there is normally:

• no Maltese foreign tax credit to claim in Belgium;

• no Belgian exemption to claim under the Belgium–Malta treaty;

• no automatic reason to treat the lump sum as tax-free in Belgium.

The UK history of the pension can still matter, but mainly for the Belgian domestic tax classification. For example, a pension originally built up in the UK and later transferred to Malta may need to be reviewed to determine whether UK pension tax relief was granted.

The key Belgian question: what type of pension payment is it?

The treaty helps determine which country may tax the income. It does not decide how Belgium taxes it.

Belgium must still classify the payment under Belgian domestic tax rules. This is usually the most important part of the analysis.

A foreign pension lump sum may potentially be treated in different ways depending on the legal and tax characteristics of the plan. It may be:

• an individual private pension or insurance-type product;

• a collective or occupational supplementary pension;

• a UK tax-relieved personal pension later transferred to Malta;

• a Maltese retirement scheme with specific pension characteristics;

• or, in substance, an investment wrapper rather than a pension.

This classification matters because the Belgian tax result can be very different. A payment may be taxed as ordinary pension income, as pension capital at a separate rate, or in some cases partly treated as a return of capital if it represents contributions made from after-tax savings without tax relief.

Belgian tax law has become more restrictive for foreign supplementary pension schemes. The Belgian tax administration has clarified that foreign collective supplementary pensions cannot simply be treated as individual life insurance products merely because the contributions were linked to the individual member.

That is why the documents behind the pension arrangement are essential.

Why UK tax relief can change the Belgian result

The contribution history is crucial.

If the foreign pension was built from the taxpayer’s own personal contributions and those contributions were made from income that had already been taxed, there may be an argument that Belgium should not tax the pure return of capital again.

However, this is not automatic.

UK private pensions often involve tax relief. In some cases, a pension provider may add basic-rate tax relief to personal contributions. In other cases, relief may have been obtained through payroll or through a UK Self Assessment tax return.

This distinction is important:

• if the original UK contributions benefited from tax relief, Belgium may be more likely to treat the later lump sum as taxable pension income or taxable pension capital;

• if the original contributions were genuinely made from fully taxed personal savings without tax relief, there may be a stronger argument for excluding at least the capital contribution element from taxable income.

The taxpayer’s own statement that no tax relief was received is useful, but it is not enough for a secure Belgian filing position. The pension provider’s documentation should confirm it.

How should the lump sum be reported in the Belgian tax return?

The exact boxes and codes for income year 2026 / assessment year 2027 will only be confirmed when the relevant Belgian tax return form is published.

Based on the current Belgian return structure described in the analysis, foreign pensions are normally reported in Box V, section A, which covers pensions, annuities, pension capital and surrender values.

Box V, section C has a different purpose. It is used for foreign pensions that qualify for a Belgian tax reduction, exemption with progression, reduced foreign income treatment, or another treaty-based mechanism. If the Belgium–Malta treaty gives Belgium the taxing right, section C would not normally be used to exempt the Maltese lump sum.

Scenario 1: fully taxable as ordinary pension income

If the lump sum is treated as ordinary taxable pension income and no separate capital rate applies, it would normally be included under the code for “other pensions, annuities, capital and surrender values taxable globally.”

In the current form referred to in the analysis, this corresponds to:

• code 1211-50 for the taxpayer column;

• code 2211-20 for the spouse or partner column, depending on whose income it is.

In that scenario, the foreign lump sum is added to the taxpayer’s other taxable income and taxed at the Belgian progressive rates.

The Belgian federal personal income tax rates mentioned in the analysis currently range from 25% to 50%, before tax reductions, exemptions and the municipal surcharge.

For a lump sum of about €89,000, this could create a substantial Belgian tax bill if no withholding tax was paid abroad.

Scenario 2: taxable as pension capital at a separate rate

In some cases, the Belgian rules may allow a pension lump sum to be treated as pension capital taxable separately.

The current Belgian form referred to in the analysis includes separate pension capital categories taxed at:

• 33%;

• 20%;

• 18%;

• 16.5%;

• 10%.

The applicable rate depends on the nature of the pension capital, the age at payment, the source of the contributions and the applicable pension rules.

For a payment made around age 60, age-related pension capital rules may be relevant. However, a taxpayer should not choose one of these separate-rate codes without first confirming the legal nature of the Maltese arrangement and the UK contribution history.

Scenario 3: partly or wholly non-taxable

If the documents confirm that the plan was funded entirely from the taxpayer’s own after-tax contributions, without any tax relief, and if Belgian rules do not treat the whole payment as taxable pension income or pension capital, there may be a basis to argue that only part of the lump sum is taxable.

In some cases, the capital contribution element may potentially be treated as non-taxable.

However, the safest approach is not to hide the payment. If the amount is treated as partly taxable or non-taxable, the Belgian return should include a clear explanatory note through MyMinfin.

That note should explain:

• the amount received;

• the year of receipt;

• the foreign paying institution;

• the pension’s foreign history;

• the absence of foreign withholding tax;

• the Belgian tax treatment applied;

• and the reason why all or part of the amount is considered non-taxable.

Belgium receives increasing amounts of automatic information from foreign financial institutions and tax authorities. An omission may lead to fines, tax increases or an assessment based on the administration’s own information.

What documents should be kept before filing?

Before filing the Belgian return for income year 2026, the taxpayer should ideally obtain and keep:

• the official Maltese pension payout statement;

• the gross amount paid and payment date;

• confirmation that no Maltese tax was withheld;

• the scheme rules or product description;

• the transfer history from the UK pension plans into Malta;

• the value transferred from each UK plan;

• the original contribution history;

• confirmation of whether contributions were personal, employer-funded, or both;

• confirmation of whether UK tax relief was granted;

• a breakdown between original contributions, investment growth and other components;

• any certificates or statements issued at the time of transfer from the UK to Malta.

The most important missing point is often whether the UK contributions benefited from tax relief. Without that confirmation, the Belgian filing position remains uncertain.

Does a separate EU or international-organisation pension change the answer?

A separate EU or international-organisation pension regime should be handled separately from a private UK/Malta pension arrangement.

A special exemption or tax regime that applies to one pension does not automatically extend to another private pension arrangement. Therefore, the existence of a separate EU or international-organisation pension does not, by itself, make a Maltese pension lump sum exempt in Belgium.

It may still affect the overall household tax calculation and the way other pension income is reported or disclosed in the Belgian tax return.

Practical conclusion

A Belgian resident who receives a Maltese pension lump sum during income year 2026 should normally address it in the Belgian tax return for assessment year 2027.

Belgium is expected to have the taxing right under the Belgium–Malta treaty. A Belgian exemption or foreign tax credit would not normally be claimed if no Maltese tax was withheld and the treaty allocates the taxing right to Belgium.

The key issue is the Belgian domestic classification:

• if the lump sum is fully taxable pension income, it may be taxed at progressive rates of up to 50%, before municipal surcharge and other adjustments;

• if it qualifies as pension capital, a separate rate such as 33%, 20%, 18%, 16.5% or 10% may apply;

• if it can be proven that the arrangement was funded from after-tax personal contributions without pension tax relief, there may be a basis to argue that at least part of the amount should not be taxed again.

Because the result depends heavily on the pension documents and the tax-relief history, it is risky to file the amount as non-taxable without supporting evidence.

Frequently asked questions

Do I need to declare a Maltese pension lump sum in Belgium if Malta withheld no tax?

Yes, if you are Belgian tax resident, the lump sum should normally be addressed in your Belgian tax return. The absence of Maltese withholding tax does not make the payment invisible or automatically tax-free in Belgium.

Is a Maltese pension lump sum automatically exempt under the Belgium–Malta treaty?

No. Based on the treaty analysis in the source, Belgium is generally expected to have the taxing right when the recipient is Belgian resident. The treaty does not automatically exempt the lump sum in Belgium.

Which Belgian tax return box is used for a foreign pension lump sum?

Based on the current return structure, foreign pensions are normally reported in Box V, section A. Box V, section C is used only where a foreign pension qualifies for a specific exemption, reduction or treaty-based mechanism.

What Belgian tax code applies if the lump sum is fully taxable?

If the payment is treated as ordinary taxable pension income, the current form referred to in the analysis points to code 1211-50 for the taxpayer column or code 2211-20 for the spouse or partner column.

Can Belgium tax my own after-tax pension contributions again?

Belgium should not automatically tax a pure return of capital as income if the contributions were made from fully taxed savings and no tax relief was granted. But this must be proven with documents, and the Belgian classification of the pension plan remains decisive.

What tax rate applies to a foreign pension lump sum in Belgium?

It depends on the classification. The amount may be taxed progressively at rates currently ranging from 25% to 50%, or it may fall under a separate pension capital rate such as 33%, 20%, 18%, 16.5% or 10%, depending on the facts.

Sources

1. FPS Finance — Foreign income and foreign pensions — https://fin.belgium.be/en/private-individuals/international/foreign-income-accounts/income

2. FPS Finance — Pension and Belgian tax return — https://fin.belgium.be/fr/particuliers/declaration-impot/situation-personnelle/pensionnes/declaration

3. FPS Finance — Filing a Belgian tax return — https://fin.belgium.be/fr/particuliers/declaration-impot/rentrer-declaration/declaration-impot

4. FPS Finance — Preparatory Belgian tax return form, pension codes — https://fin.belgium.be/sites/default/files/media/documents/doc-preparatoire-partie-1-rf-2026.pdf

5. Malta legislation — Belgium-Malta double taxation treaty text — https://legislation.mt/eli/sl/123.5/eng/pdf

6. SPF Finance circular 2022/C/95 on foreign supplementary pensions — https://blog.forumforthefuture.be/fr/article/circulaire-2022c95-relative-au-traitement-fiscal-en-droit-interne-des-engagements-collectifs-de-pension-complementaire-etrangers/16189

7. FPS Finance — Belgian personal income tax rates — https://fin.belgium.be/en/private-individuals/tax-return/income/tax-rates

8. GOV.UK — UK private pension tax relief — https://www.gov.uk/tax-on-your-private-pension/pension-tax-relief

9. European Parliament — Protocol No 7 on the privileges and immunities of the European Union — https://www.europarl.europa.eu/cmsdata/199083/A2_EN.PDF

This article provides a general framework and does not constitute a personalised tax opinion. Tax rules and forms can change from year to year, and the correct treatment depends on the exact pension documents, contribution history and personal situation.

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