A tax reform amending the statute of limitations and CCP framework has been adopted
17 Dec 2025
The draft law of 3 July 2025 containing various tax and financial provisions was adopted on 9 December. It contains key changes regarding investigation, assessment and retention periods, as well as the Central Contact Point (CCP).
Investigation, assessment and retention periods
As noted in our previous newsflash (https://www.pwclegal.be/en/news/investigation--assessment-and-retention-periods---back-to-how-it.html), the Belgian Parliament adopted on 14 October 2025 a series of measures on tax and financial provisions that largely reverse the 2022 reform of the statutes of limitation in direct tax and VAT procedures. The new provisions replace the layered 3/4/6/10-year regime introduced as of assessment year 2023, and partially reinstate the previous regime.
The new investigation and assessment periods are as follows:
- 3 years: ordinary investigation and assessment period for timely filed returns.
- 4 years for late or non-filed returns and for all “complex” returns (which includes the former “semi-complex” returns).
- 7 years in case of fraud.
Furthermore, the retention period for books and records is reverted to 7 years, thereby abandoning the 10-year period introduced in 2022.
These new periods apply retroactively from assessment year 2023, meaning that the 2022 reform will in practice never have taken effect.
It is important to note that the investigation and assessment periods applicable to Pillar 2 obligations are set to 6 years in the draft law of 9 October 2025, amending the Act of 19 December 2023 on the minimum tax for multinational enterprises and large domestic groups. This six-year period is justified by the exceptional complexity and international dimension of Pillar 2 audits. These provisions have not yet taken effect.
Central Contact Point (CCP)
The recently adopted law also provides for a significant expansion of the Central Contact Point (CCP), a database managed by the Belgian National Bank containing information on Belgian accounts and financial contracts of natural and legal persons provided by financial institutions, as well as foreign accounts declared by Belgian residents.
The newly adopted provisions broaden the scope of the financial data captured in the CCP by explicitly mentioning that individual securities accounts and crypto accounts must now also be reported.
The tax authorities already had the possibility to access CCP data under certain conditions, and following a strict procedure, and use it for the purposes of direct and indirect tax audits. This data will now also be accessible by tax officials responsible for establishing and auditing the securities accounts tax and particularly the anti-abuse provisions. However, contrary to what applies for other tax audits, no conditions or guarantees are provided for those officials in order to access the CCP data. This could potentially be seen as a discrimination.
That being said, the CCP data will be used to strengthen fight against tax fraud and money laundering. A legal framework was created allowing a dedicated team of data miners to perform anonymous analyses of CCP data and cross-reference it with other databases of the tax authorities to identify risk profiles and patterns that may signal potential fraud. The results will be used to select files for individual investigation. This measure has particularly been criticized by the Belgian Data Protection Authority that voiced concerns on possible privacy violations.
Key takeaways
The reinstatement of the previous limitation periods provides welcome clarity and simplification, but Belgian tax statutes of limitations remain complex due to numerous conditions and exceptions.
Simultaneously, the CCP reform underlines the tension between the need to strengthen the effectiveness of tax audits and the necessity to protect taxpayers’ rights, primarily the right to privacy. In times of increased data gathering and processing by tax authorities, it will be crucial for taxpayers to stay vigilant and uphold their fundamental rights.
Don’t hesitate to contact us for further guidance or questions regarding these changes.
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