VVPR-bis: Rate Increased to 18%
The Program Law of 30 May 2026 introduces important changes to the VVPR-bis regime following months of political negotiations and postponement. The reduced dividend withholding tax rate increases from 15% to 18% for distributions made as of 1 July 2026.
Recap: What is VVPR-bis?
VVPR-bis is a regime that allows small companies to distribute dividends at a reduced withholding tax rate (instead of the standard 30%), provided certain conditions are met, including a.o. that the company qualifies as small at the time of incorporation or upon a capital increase (the size assessment is therefore a one‑time snapshot that does not need to be reassessed at the time of the actual distribution), a cash contribution, and a minimum holding period of three financial years.
Under the Program Law, the reduced withholding tax rate is increased from 15% to 18% for distributions as of 1 July 2026.
What to do?
Dividends distributed before 1 July 2026 may still benefit from the 15% rate. It is therefore advisable to proactively review the timing and your dividend strategy together with us (for example, to assess whether an accelerated dividend distribution remains feasible and appropriate in your specific situation).
As a result, distributing dividends under the VVPR-bis regime becomes less tax-efficient, and alternative strategies should once again be given (greater) consideration.
If you would like to understand how these changes may affect your company or personal situation, our experts are here to help. Reach out to us discuss your options and determine the most suitable dividend strategy for your circumstances.
