What is the securities tax?
The annual tax on securities accounts (ATSA) is a levy on holding financial instruments through a securities account. It applies to all accounts whose average value over the reference period (from 1 October to 30 September, with the value assessed at the end of each quarter) exceeds one million euros. As soon as that threshold is exceeded, the 0.15% tax applies to the full value of the account. Shares, bonds, investment funds and other products managed through a securities account fall within its scope.
New anti-abuse rules
The legislator wants to prevent investors from falling outside the scope through technical manoeuvres. Two practices in particular are targeted:
1. converting securities in an account into registered securities;
2. splitting or transferring accounts so that the value falls below the threshold.
When such transactions take place with an account of more than one million euros, the tax authorities automatically assume that the intention is to avoid the tax. This presumption can be rebutted but it is up to the taxpayer to prove that the decision was not tax-related. One example would be a donation where the parent retains the usufruct, or a split arising from divorce or death.
Reporting obligation since summer 2025
In addition to the anti-abuse rules, the legislator is also introducing a reporting obligation. Since July 2025, banks and financial institutions must report every conversion or transfer of securities accounts above the €1 million threshold to the tax authorities. This report must be made within one month and applies regardless of whether or not the transaction is fiscally motivated.
For accounts held abroad, the responsibility lies directly with the account holder. Anyone managing an account outside Belgium must therefore report the transaction themselves.
The consequences of this obligation are significant
For banks it means an additional administrative burden and failure to report on time may result in a fine ranging from €250 to 2,500.
For investors the main change is in how transactions are assessed: transactions that were previously regarded as purely organisational are now placed under closer scrutiny. In addition, the account holder bears the burden of proof to demonstrate that the transaction was not solely intended to avoid the tax.
More transparency via CAP
On top of that, the tax authorities gain greater access to the Central Point of Contact (CPC) of the National Bank. Banks and institutions are required to provide the requested data, enabling the Administration to verify more quickly and efficiently whether the securities tax return has been filed correctly.
What does this mean in practice?
The rate and the basis of the securities tax remain unchanged, but the way the tax authorities monitor compliance has fundamentally changed. Transactions above the threshold are closely monitored, banks have a reporting obligation and account holders must be able to demonstrate that their transactions have a valid reason. Anyone who fails to report on time or cannot provide a convincing justification risks both financial penalties and a reclassification of the transaction as abuse.
Conclusion
The July 2025 reform places the focus on control and compliance. The government wants to prevent the securities tax from being undermined by creative arrangements and gives the tax authorities more leverage through reporting obligations and access to data.
The offices of PIA Group and the experts of PIA Advisory are closely monitoring these developments and are ready to assist you in meeting the new obligations correctly. This way you avoid unpleasant surprises while remaining fully compliant so please do not hesitate to contact us.
