Foreign bank accounts and exit tax

The holding of foreign bank or financial accounts by Belgian residents is subject to increasingly strict regulations. For several years now, Belgian taxpayers have been required to declare the existence of foreign accounts via the Central Contact Point (CCP) of the National Bank. This obligation, often perceived as purely formal, is now taking on greater importance in the context of the intensified fight against tax evasion.

The Belgian tax authorities now benefit from the automatic exchange of information with many countries, both at European and international level. Account balances, financial income and significant movements are systematically transmitted. In practice, failure to declare a foreign account is increasingly easy to detect and can result in administrative, tax or even criminal penalties in cases of bad faith.

At the same time, the debate on the introduction or strengthening of an exit tax regularly resurfaces. The principle is well known: when a taxpayer transfers their tax residence outside Belgium, unrealised capital gains on certain assets could be taxed as if they had been realised at the time of departure. This mechanism already exists in part for companies, but could be extended or clarified for individuals with significant financial assets.

For business leaders and private investors, these developments mean they need to be extra vigilant. Poorly planned wealth management or expatriation can have significant tax consequences, sometimes retroactive. It is essential to anticipate reporting obligations, identify assets that may be subject to exit tax, and structure transactions in accordance with the existing legal framework.