Tax Shelter yield slightly drops below 13%
Investors who carry out an operation and whose payment is made between July 1 and December 31, 2025, will benefit from a net overall gain of 12.83%. A return that remains historically high despite a drop in the 12-month Euribor during the previous semester, which serves as the basis for the calculation.
Last update on : 04.07.2025
There is nothing new regarding the tax return from the operation. The exemption rate (421%) applied to the invested amount is higher than the marginal tax rate of 25% (corporate income tax). Result: the amount invested in the Tax Shelter is lower than the amount of tax exemption, resulting in a positive gain of 5.25% for the investor.
Let’s consider a company taxed at the standard rate of 25%.
If it generates a pre-tax profit of €1,000,000, it will have to pay €250,000 in taxes to the State.
If it chooses to invest €100,000 in a Tax Shelter, it will be able to fiscally exempt €421,000. Indeed, since tax year 2021, the exemption rate for the Tax Shelter stands at 421%.
Therefore, its taxable base after Tax Shelter is reduced to €1,000,000 – €421,000 = €579,000.
Let’s calculate the corporate tax on this new amount: €579,000 x 25% = €144,750.
Now add to this tax the amount invested in the Tax Shelter paid to the film producer: €144,750 + €100,000 = €244,750.
The tax return from the Tax Shelter operation is: €250,000 – €244,750 = €5,250.
Thanks to the Tax Shelter operation, the investor gains €5,250, or 5.25% of their investment.
Last update on : 04.07.2025
But that’s not all!
The Tax Shelter legislation (Article 194ter et seq. of the Belgian Income Tax Code - CIR92) provides the possibility for the producer to supplement the tax return with a conditional additional financial return.
This is not a requirement, but rather an option the producer can use to make the Tax Shelter more attractive to investors.
All intermediaries active in the market today follow the same policy: paying investors the legal maximum. So take advantage of it!
In practice, the law sets a maximum rate, recalculated every six months (January 1 and July 1), based on the 12-month Euribor from the previous semester.
The financial return begins from the date the investment is transferred to the producer’s account and continues until the issuance of the final tax certificate by the FPS Finance, with a maximum period of 18 months.
In most cases, the financial return is paid after 18 months—before the final tax certificate is issued—thus closing the operation.
For payments made between July 1 and December 31, 2025, the financial premium amounts to 10.108% gross of the invested amount.
On this income, considered a financial gain, the investor will pay corporate tax (25%) in the year it is received.
The net financial premium, received 18 months after the Tax Shelter investment, amounts to 7.581%.
5.25% + 7.581% = 12.831%
Last update on : 04.07.2025
In Belgium, not making advance tax payments can be costly. For tax year 2026, companies must pay a surcharge of 6.75% on any tax due if insufficient advances were paid.
Since the Tax Shelter reduces the taxable base, it also reduces the surcharge amount.
It is therefore highly advantageous for companies to consider a Tax Shelter investment if they realize at the end of their fiscal year that they will be subject to such a penalty.
The net overall return of a Tax Shelter operation for a company with insufficient advance payments can reach 22%!
Last update on : 04.07.2025
Finally, remember there is a double ceiling on the amount a company can fiscally exempt through a Tax Shelter:
What if your Tax Shelter investment exceeds one of these limits?
In such cases, the law allows you to carry forward the excess to a later fiscal year, for up to four subsequent years.
You must therefore pay attention in future years to first use your carried-forward surplus before considering a new investment.
This calculation can be done with the help of your Tax Shelter Investment Consultant at SCOPE Invest.
Last update on : 04.07.2025