Black money back white? The new tax regularization procedure explained

After months of uncertainty, the decision has been made: tax regularization is back, this time in a permanent and formal legal framework. The Program Law of July 18, 2025, brought an end to a long period without a clear way forward for rectifying tax files. In this blog, attorney Dirk Merckx explains exactly what the new regulations entail and why caution remains essential. “For many, this finally means clarity and legal certainty once again: the basis for looking ahead with confidence.”

The Program Law of July 2025 finally brought about change in this regard: since July 29, files can once again be resubmitted via the regularization contact point. The regulation applies at the federal level for personal income tax, corporate income tax, and VAT; a regional regulation is still being developed for inheritance tax.

According to Dirk Merckx, the permanent nature of the scheme is a major step forward: “Clients no longer have to wait for new initiatives. This stable framework once again offers the peace of mind and legal certainty that are so necessary in practice.”

Tax regularization: two categories, two consequences

An essential distinction within the procedure is that between tax-prescribed capital and non-prescribed income.

• Prescribed capital is credit that is no longer subject to taxation within the statutory assessment periods; a flat rate of 45% applies to this.
• Non-statute-barred income, on the other hand - such as interest and dividends that can still be taxed within the statutory deadlines - is taxed at the normal rate for the relevant income years, increased by 30%.

This distinction may seem technical, but in practice it determines the full financial impact of a case. Careful analysis and compilation of the case is therefore crucial.

Once approved, the applicant receives a regularization certificate. This certificate grants not only tax immunity, but also criminal immunity. In practice, it also serves as an entry ticket to bring funds back into Belgian banks and pass the scrutiny of their compliance services.

After a year and a half of uncertainty, the program law of July 2025 creates fiscal certainty and predictability.

Regularization scheme with a fixed route and precision as the key

The regularization procedure remains largely the same as before: declarations can only be made as long as no tax or criminal investigation is ongoing.

Our experience at NOMA shows that cooperation with the contact point is generally constructive and professional. This creates trust and predictability, valuable anchors in a domain where uncertainty often sets the tone.

Nevertheless, vigilance is required: every regularization file requires precision and experience, every detail counts. “An incomplete or incorrect approach can undermine legal certainty. Professional guidance is not a luxury, but a necessity,” says Dirk Merckx. This fifth round once again opens the way to tax peace of mind, but success depends on the right approach.

Are you considering making use of this regularization scheme? NOMA will guide you discreetly and decisively in compiling your file. Please contact us.