Executive remuneration: what trade-offs will arise in 2026–2027 following the reforms?

Executive remuneration remains a key tool for tax and social security optimisation. However, recent and forthcoming changes to the Belgian tax framework necessitate a reassessment of the traditional balance between remuneration, dividends and benefits in kind.

In this context, the trade-offs for 2026–2027 can no longer be considered in isolation: they must form part of a comprehensive approach that integrates taxation, cash flow and wealth management objectives.

A long-standing balance called into question

Traditionally, optimisation was based on a structured combination:

•    minimum remuneration allowing access to the reduced corporation tax rate;

•    supplementary distribution via dividends;

•    and, where applicable, the provision of benefits in kind (car, accommodation, etc.).

This model remains valid in principle, but the parameters have changed:

•    increased pressure on benefits in kind (higher valuation);

•    changes in dividend rates and conditions;

•    greater scrutiny by the tax authorities regarding the overall consistency of remuneration.

Remuneration vs dividends: an analysis requiring further refinement

The trade-off between remuneration and dividends must now take several factors into account:

•    Remuneration:

Tax-deductible for the company, but heavily taxed at the individual level (personal income tax + social security contributions).

It remains, however, essential for:

•    securing the reduced corporate tax rate;

•    building up social entitlements (pension, social security cover).

•    Dividends:

More straightforward taxation (withholding tax), but not deductible at company level.

Their suitability depends in particular on:

•    available reserves;

•    the applicable regime (VVPRbis, liquidation).

Tax planning can therefore no longer be standardised: it must be assessed on a case-by-case basis, depending on the executive’s profile and the company’s circumstances.

Benefits in kind: under increasing pressure

Benefits in kind remain an attractive optimisation tool, but their appeal is waning:

•    increases in the tax bases (particularly for vehicles);

•    reduction in certain tax benefits;

•    actual economic cost sometimes underestimated.

A total cost analysis is becoming essential: a tax-efficient benefit may prove less relevant once the overall cost to the company is taken into account.

Towards an integrated approach to remuneration

Decisions for 2026–2027 must now take into account:

•    the director’s personal tax situation;

•    the company’s tax situation;

•    cash flow requirements (short- and long-term);

•    wealth management objectives (distribution vs capitalisation).

With this in mind, certain strategies are becoming increasingly relevant:

•    spreading remuneration over time;

•    a gradual combination of remuneration and dividends;

•    targeted use of benefits in kind where their cost remains under control.