Reynders Tax vs Capital-Gains Tax in Belgium: Do They Overlap or Do You Pay Twice?

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Last updated: 2026-05-17 · Reading time: 11 min · Topic: Reynders tax, capital-gains tax, bond ETFs · For: Belgian investors with funds or ETFs

On this page

  1. Two taxes, one capital gain — where is the overlap?
  2. The Reynders tax (art. 19bis ITC92): what does it cover?
  3. The new capital-gains tax (Law of 6 April 2026): what does it cover?
  4. The non-cumulation rule in plain English: art. 96/2, first paragraph, 6° ITC92
  5. Three calculation methods for a fund or ETF
  6. Worked examples: pure equity ETF, pure bond ETF, mixed fund
  7. Who withholds what? Belgian broker vs foreign broker
  8. Practical checklist
  9. Sources & further reading

Lead

From 1 January 2026, a Belgian retail investor who sells a bond ETF is in principle liable for two taxes: the Reynders tax of 30% (Reynders-taks, article 19bis ITC92 (Income Tax Code 1992)) on the interest component, and the new capital-gains tax of 10% (Law of 6 April 2026) on the remainder of the gain. At first glance, that looks like double taxation. In practice, it works differently: the law contains a non-cumulation rule (art. 96/2, first paragraph, 6° ITC92) that prevents the same euro from being taxed twice.

For pure equity ETFs (VWCE, IWDA, SPY, …) nothing changes on the Reynders front: those funds do not fall under article 19bis in any case. For them, only the new 10% regime applies. For mixed funds and all funds with more than 10% in bonds, things become more complex — three different calculation methods are possible, depending on what the fund manager publishes.

This page explains how the two regimes work side by side in 2026, who must declare what, and which pitfalls to watch out for before selling a bond ETF or a mixed fund.

Two taxes, one capital gain — where is the overlap?

Before 1 January 2026, the Reynders tax was the only Belgian tax regime on capital gains from a fund or ETF (besides the tax on stock-exchange transactions (TOB)). A pure equity ETF was therefore sold tax-free on realisation; a bond ETF was taxed at 30% on the bond component.

With the introduction of the capital-gains tax on financial assets via the Law of 6 April 2026, published in the Belgian Official Gazette (BS) on 21 April 2026 (source in Dutch, accessed 2026-05-17), the legislature faced a choice: either abolish the Reynders tax (article 19bis ITC92) or keep both taxes and introduce a coordination rule. Earlier government texts had spoken of abolishing the Reynders tax, but according to the Tiberghien analysis of 4 July 2025 (source in Dutch, accessed 2026-05-17), the final legislative choice was to keep both regimes — with a non-cumulation rule to prevent double taxation.

The principles are straightforward:

  • Pure equity ETF (no bond component) → 10% capital-gains tax only (above the €10,000 exemption).
  • Pure bond ETF (purchased from 1 January 2018) → 30% Reynders on the interest component (TIS difference) + 10% capital-gains tax on the residual gain.
  • Mixed fund with ≥10% in bonds (purchased from 1 January 2018) → same: split between 30% Reynders and 10% CGT (capital-gains tax).

The difficulty lies not in the principle but in determining exactly what falls under the “interest component”. That is where art. 96/2, first paragraph, 6° ITC92 comes in — a non-cumulation rule that first carves the Reynders base out of the overall gain, so that the 10% CGT applies only to the excess.

The Reynders tax (art. 19bis ITC92): what does it cover?

The Reynders tax levies 30% on the Belgian TIS (Taxable Income per Share) of the bond portion of a fund or ETF, at the moment of sale, conversion, or redemption. The TIS includes both interest and capital gains from debt instruments — not just interest in the narrow sense. The tax takes its name from Didier Reynders, the former Finance Minister who introduced it in 2006.

Two thresholds determine when Reynders applies, depending on when you purchased the fund, according to the Wikifin page on taxes on Belgian investments (source in Dutch — no English version available, accessed 2026-05-17):

  • Purchased from 1 January 2018: Reynders applies as soon as the fund invests at least 10% in debt instruments.

  • Purchased before 1 January 2018: the older threshold of 25% applies. A mixed fund with 15% in bonds that you bought in 2016 therefore does not fall under Reynders. (The 25% threshold was historically linked to the now-repealed EU Savings Directive 2003/48/EC, but it remains as a threshold criterion in art. 19bis ITC92 for pre-2018 purchases.)

For the calculation, the Belgian tax authorities look at the TIS value published by the fund manager. According to Curvo (accessed 2026-05-17 — temporarily inaccessible — bot-block 403 confirmed 2026-05-26 ; verify in-browser before relying on this URL) and the Bolero page on taxable products (source in Dutch, accessed 2026-05-17), the difference between the TIS at the date of purchase and the TIS at the date of sale is multiplied by 30%. No TIS published? The tax authority then falls back on a method based on the average bond percentage (see § 5 below).

Practical take-away: for the Reynders question, only the type of fund matters (equity, bonds, mixed), not your broker. For who withholds the tax, your broker is decisive — we return to that in § 7.

The new capital-gains tax (Law of 6 April 2026): what does it cover?

The Law of 6 April 2026 introducing a tax on capital gains on financial assets (source in Dutch) (Belgian Official Gazette 21 April 2026, accessed 2026-05-17) introduces a new category of miscellaneous income in article 90 ITC92. The regime works as follows:

  • Rate: 10% on the realised capital gain on sale, conversion, or redemption of financial assets.
  • Scope: equities, bonds, funds, ETFs, capitalisation SICAVs, Branch 21 and Branch 23 savings contracts (in part), crypto-assets.
  • Annual flat exemption: €10,000 per taxpayer, buildable up to €15,000 over 5 years (source in Dutch, accessed 2026-05-17). Unused? Each year you can carry forward €1,000 of unused balance to the following year, capped at €15,000.
  • Entry into force: 1 January 2026. Historical gains up to and including 31 December 2025 do not fall under the regime — the value on 31/12/2025 (snapshot value (foto-waarde)) serves as the new cost basis. See the Deutsche Bank overview of the capital-gains tax (source in Dutch, accessed 2026-05-17) for the transitional arrangements.

The new regime therefore in principle covers all capital gains on financial assets, including the gain on a bond ETF that already falls under Reynders. Without a coordination rule, the same euro of profit would be taxed twice: once at 30% (Reynders, on the interest component) and once at 10% (CGT, on the overall gain). The legislature expressly wanted to avoid this overlap.

The non-cumulation rule in plain English: art. 96/2, first paragraph, 6° ITC92


The Law of 6 April 2026 adds, via art. 10 (NUMAC 2026002780, Belgian Official Gazette 21 April 2026), a new paragraph to article 96/2 ITC92. According to the analysis by Denis-Emmanuel Philippe (Tax News, May 2026) (source in Dutch, accessed 2026-05-17), art. 96/2, first paragraph, 6° ITC92 provides that income already taxable as movable income (including the TIS component taxed under article 19bis ITC92) is excluded from the CGT base before the 10% rate is applied.


Translated into a rule of thumb, for a single bond or mixed fund sale in 2026, the steps are:

  1. Calculate the total capital gain (sale price − snapshot value 31/12/2025 or later purchase price, whichever applies).
  2. Calculate the TIS difference (TIS at sale date − TIS at purchase date, in currency).
  3. 30% Reynders is levied on the TIS difference.
  4. The CGT base = total capital gain − TIS difference. 10% CGT is levied on this (after deduction of the annual €10,000 exemption).


Practical analyses by Tiberghien (New capital-gains tax takes shape and Reynders tax rises from the ashes (source in Dutch, accessed 2026-05-17)) and Denis-Emmanuel Philippe (Interaction between the Reynders tax and the capital-gains tax (art. 96/2, first paragraph, 6° ITC92) (source in Dutch, accessed 2026-05-17)) confirm that the effective combined rate on a typical bond ETF is lower than the naive sum of “30% + 10%”: you pay 30% on a small slice (the TIS component) and 10% on the rest, not 40% on the whole.


Important: the €10,000 exemption applies only to the CGT base, not to the Reynders base. Anyone who has already used up the exemption on other financial assets pays 10% on the full residual gain from the fund sale.

Three calculation methods for a fund or ETF

Not every fund manager publishes a daily TIS. Based on the Value Square analysis “What changes in the taxation of your fund and ETF?” (source in Dutch, accessed 2026-05-17), the tax authority applies three cascade methods:

Method 1 — TIS value (preferred). When the fund manager calculates and publishes a daily TIS value, the broker uses it for the split. Reynders 30% on the TIS difference, CGT 10% on the residual.

Method 2 — Asset test / fall-back method (fall-back).


No daily TIS? The tax authority then looks at the average percentage of the fund invested in bonds and cash over the preceding reference period (per Wikifin / FSMA source 2026-05-17). That percentage is multiplied by the overall capital gain, and Reynders 30% applies to that amount. The remainder falls under CGT 10%. Note: Value Square uses the narrower definition of “bonds only” in its own analysis. For cash-heavy funds, this can make a significant difference; consult the fund manager or a tax adviser if in doubt.

Method 3 — Full Reynders (fall-back of the fall-back). No TIS and no asset test possible? The tax authority applies 30% Reynders to the entire capital gain — in that case no residual remains for the 10% CGT. This is fiscally the least favourable scenario for the investor and mainly arises with foreign funds whose composition is not transparently reported.

Practical take-away: investors holding a bond ETF from a large issuer (iShares, Vanguard, Amundi, SPDR) are usually in Method 1 — a TIS statement is generally available via the Belgian broker. For obscure or non-UCITS funds, Method 3 is a real risk.

Decision tree: Reynders tax or capital-gains tax (or both)? Decision tree with three questions: does the fund hold more than 10 percent bonds, is a TIS value available, and which rate applies. Does the fund hold ≥ 10% bonds? (purchases from 1 Jan 2018) NO Pure equity ETF No Reynders. 10% CGT only YES TIS value available? (fund manager publishes) YES Method 1 — TIS 30% on TIS difference + 10% on residual (non-cumul art. 96/2, first para., 6°) NO Method 2 or 3 Asset test or full 30% Reynders (least favourable) Source: art. 19bis + art. 96/2, first para., 6° ITC92 + Law of 6 April 2026
Decision tree for the Belgian retail investor: determine before selling whether Reynders applies and which method the tax authorities will use.

Worked examples: pure equity ETF, pure bond ETF, mixed fund

Three scenarios for a sale in 2026, all starting from the snapshot value on 31/12/2025 as the cost basis (transitional rule). For simplicity we assume the annual €10,000 exemption has not yet been used up.

Example A — Pure equity ETF (VWCE)

  • Snapshot value 31/12/2025: €20,000
  • Sale price 30/06/2026: €23,000
  • Realised capital gain: €3,000

Reynders tax: not applicable (no bond component).
Capital-gains tax: €3,000 falls entirely within the annual exemption of €10,000 → €0 due.

A small profit on a pure equity ETF therefore remains tax-free as long as the annual exemption is not exceeded.

Example B — Mixed bond fund (Bolero example 2026)

Based on the Bolero example for capital-gains tax on funds (source in Dutch, accessed 2026-05-17), which Bolero itself frames as “a mixed bond fund or ETF that holds both equities and bonds“:

  • Purchase 2026: €2,000
  • Sale 2028: €2,500
  • Realised capital gain: €500
  • TIS at purchase: 120 → TIS at sale: 160 → TIS difference: €40

Reynders tax: €40 × 30% = €12.
Capital-gains tax: (€500 − €40) × 10% = €46 (on the residual gain, after deduction of the TIS component).

Total: €58 on a gain of €500 → effective rate 11.6%.

Under a naive cumulation without the non-cumulation rule you would pay €500 × 30% + €500 × 10% = €200 — almost 3.5× as much. The non-cumulation rule of art. 96/2, first paragraph, 6° ITC92 does its job here.

Example C — Mixed fund (50% equities / 50% bonds + cash, asset test)

Suppose: a fund without a daily TIS publication. The combined percentage in bonds + cash (per Wikifin/asset test) amounts to 50%.

  • Purchase: €10,000 (snapshot value 31/12/2025)
  • Sale 2027: €12,000
  • Realised capital gain: €2,000

Reynders tax (Method 2 — asset test): 50% × €2,000 = €1,000 as Reynders base. €1,000 × 30% = €300.
Capital-gains tax: €2,000 − €1,000 = €1,000 as CGT base. If within the €10,000 exemption → €0.

Total: €300 on a gain of €2,000 → effective rate 15%.

The asset test is by definition less precise than the TIS method and generally turns out less favourable for the investor.

Who withholds what? Belgian broker vs foreign broker

The split between Reynders and CGT has to happen somewhere in practice. Two scenarios:

With a Belgian intermediary (Bolero, Keytrade, Belfius, KBC, MeDirect, Belgian branch of Saxo): the broker in principle performs both withholdings at source. Reynders has been in the automatic withholding regime since 2006; the 10% CGT falls under the broker-withholding regime from 1 June 2026 (art. 35 Law of 6 April 2026, accessed 2026-05-17). Concretely: when selling a bond ETF you will see two separate lines on your account statement — Reynders and capital-gains tax.

With a foreign broker without a Belgian representative (DEGIRO, Trade Republic, Interactive Brokers Ireland): you are personally liable to declare both taxes. The Reynders tax is declared in Section VII of the personal income tax return using the TIS statement from the fund manager;

the 10% capital-gains tax via Section XV — the exact box code for the new CGT will follow in the tax-return guide (aangiftegids) for FY-2027 (assessment year FY-2027) (FPS Finance tax-return guide for FY-2027 not yet published as at 2026-05-17 — exact box number to follow; check finance.belgium.be/en before filing).

DEGIRO, for instance, does automatically handle the TOB on purchases and sales, but not Reynders and (at the date of publication) not the new CGT either.

Practical take-away: anyone holding a larger bond or mixed-fund portfolio outside Belgium will, from FY-2027 onwards, have a personal income tax return with significantly more lines than before. Collect both the TIS statements and the transaction overviews from your broker for every sale in 2026 — you will need both sources.

Practical checklist

  • [ ] Fund type determined? Pure equity ETF → 10% CGT only. Bond fund, mixed fund, or fund with >10% debt (purchased from 1 January 2018) → split Reynders + CGT.
  • [ ] Snapshot value 31/12/2025 recorded? Keep your broker statement or valuation of 31/12/2025 as the new cost basis for the CGT calculation — without it you lose the transitional arrangement.
  • [ ] TIS statement collected? For every fund with a bond component — request it from your broker or directly from the fund manager (iShares, Vanguard, Amundi, SPDR publish this in their tax documents).
  • [ ] €10,000 exemption tracked? The annual exemption applies only to the CGT base, not to the Reynders base. Prefer selling pure equity ETFs first to use up the exemption.
  • [ ] Foreign broker? Both declaration obligations fall to you. Reserve time in June–August 2027 for the FY-2027 tax return.
  • [ ] If in doubt: ask your broker which method (TIS / asset test / full Reynders) they apply — the difference can amount to hundreds of euros per sale.

Sources & further reading

Primary sources

Secondary analyses (lawyers + tax advisers)

Broker and fund documentation (TIS mechanics + worked examples)

Related articles on investnow.be

  • Reynders tax explained: 30% on the bond portion of funds (NL: /reynders-taks-uitgelegd/)
  • Belgian investment taxation — pillar (NL: /belgische-beleggingsbelastingen/)

  • €10,000 capital-gains tax exemption: splitting between partners + harvesting (TX-03 — not yet published as at 2026-05-17)

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