SRL Director Remuneration in Belgium: Salary, Dividends or Both?

One of the most strategic decisions for the director of an SRL (Société à Responsabilité Limitée, Belgium's private limited company) is how to structure their remuneration. Should you pay yourself a high salary, distribute dividends, or combine both? Each option carries different tax and social security implications, and the wrong choice can cost thousands of euros. This detailed guide helps you optimise your director remuneration within the 2026 Belgian tax framework.

The legal framework: the SRL under the CSA

The SRL under the Companies and Associations Code (CSA)

Since the Companies and Associations Code (CSA) came into force on 1 May 2019, the SRL has replaced the former SPRL. The main differences affecting director remuneration are:

• No more minimum capital: the SRL no longer has a statutory minimum capital (against EUR 18,550 for the former SPRL). Instead, the CSA requires sufficient opening equity (art. 5:3 CSA), validated by a financial plan.
• Dividend distribution: subject to a double test (net asset test and liquidity test, art. 5:141 and 5:142 CSA).
• "Administrateur" (no longer "gérant"): the legal term for an SRL is now "administrateur" (director), although "gérant" (manager) remains common in practice.

The three pillars of remuneration

Pillar 1: Director remuneration (salary)

The remuneration paid by the SRL to its director is a deductible expense for the company and taxable professional income for the director.

Tax treatment:

On the company side:

• The remuneration is deductible as a business expense (art. 49 CIR 92)
• It reduces the taxable base for corporate income tax (ISOC)
• The company pays payroll withholding tax (précompte professionnel) on the remuneration

On the director's side:

• The remuneration is taxed under personal income tax (IPP) at progressive rates:

• Self-employed social security contributions: around 20.50% on net income (up to EUR 70,857.99), then 14.16% (from EUR 70,857.99 to EUR 104,422.24), then 0% above the ceiling
• Municipal surcharges (centimes additionnels), which vary by municipality

Pillar 2: Dividends

Dividends are a distribution of the company's after-tax profit. They are subject to withholding tax at source (précompte mobilier).

Tax treatment:

On the company side:

• Dividends are not deductible from the taxable base
• They are paid out of profit after corporate income tax

On the director's side:

• 30% withholding tax deducted at source (art. 269, para. 1, 1 CIR 92)
• No social security contributions on dividends
• No additional personal income tax (the withholding tax is final)

Pillar 3: The VVPR-bis regime (reduced-rate dividends)

The VVPR-bis regime (Verlaagd tarief – Verminderde Voorheffing / reduced rate – reduced withholding tax) allows dividends to be distributed at a reduced withholding tax rate:

VVPR-bis conditions (art. 269, para. 2 CIR 92):

• Contributions must be made in cash (not in kind)
• Shares must be registered
• They must be new shares issued for a capital contribution made from 1 July 2013 onward
• Shares cannot be preferred shares
• The company must be an SME within the meaning of article 1:24 of the CSA

Example: your SRL, set up in 2024 with a cash contribution of EUR 10,000, makes a profit in 2026. Dividends distributed in 2027 (the 3rd financial year after the contribution) will benefit from the 15% rate instead of 30%.

The EUR 45,000 minimum remuneration: how does it work?

The principle (art. 215, para. 3 CIR 92)

To benefit from the reduced 20% corporate tax rate on the first EUR 100,000 of profit, one of the conditions is that the SRL pays remuneration of at least EUR 45,000 to at least one of its individual directors.

If the remuneration is below EUR 45,000, the company is subject to a separate contribution of 5.1% on the difference between EUR 45,000 and the remuneration actually paid (or on the taxable profit if this is lower than EUR 45,000).

Calculating the separate contribution

Exception: starters

Companies that are small companies within the meaning of article 1:24 of the CSA, and that are within their first 4 financial years, are exempt from the separate contribution. This is a favourable measure for starters.

Exception: remuneration of at least half of profit

If the remuneration paid to the director is at least equal to half the company's taxable profit (before deducting the remuneration), the separate contribution is not due, even if the remuneration is below EUR 45,000.

Comparative simulation: salary vs dividends

Take the case of an SRL generating a gross profit of EUR 100,000 (before director remuneration). The director is single and has no other income.

Option A: EUR 100,000 remuneration, no dividends

Option B: EUR 45,000 remuneration + dividends

Option C: EUR 45,000 remuneration + VVPR-bis dividends (15%)

Comparative summary

Conclusion: the combination of salary plus dividends is significantly more advantageous, and the VVPR-bis regime adds a considerable extra benefit.

Benefits in kind (ATN): a remuneration top-up

What is an ATN?

A benefit in kind (avantage de toute nature, ATN) is a non-monetary benefit granted by the company to its director, valued on a flat-rate basis and added to taxable remuneration.

The main benefits in kind and how they are valued

The company car benefit: an important special case

The company car is the most common and most complex benefit in kind. Its value is calculated as follows:

Formula: Catalogue value x 6/7 x CO2 % x age coefficient

The CO2 percentage is calculated as follows:

• Petrol/petrol-hybrid vehicles: 5.5% + (CO2 emissions – 91) x 0.1% (min. 4%, max. 18%)
• Diesel/diesel-hybrid vehicles: 5.5% + (CO2 emissions – 91) x 0.1% (min. 4%, max. 18%)
• Fully electric vehicles: 4% (minimum)

The age coefficient reduces the catalogue value by 6% a year (minimum 70% of the catalogue value).

Example: a new Tesla Model 3 (electric, 0 g CO2) with a catalogue value of EUR 45,000:

• Benefit value = 45,000 x 6/7 x 4% x 100% = EUR 1,542.86/year (around EUR 128/month)

Since the law of 25 November 2021 (greening of car taxation), only fully electric vehicles remain fully deductible for companies (from the 2026+ financial years, the deductibility of combustion-engine cars is being progressively reduced).

Alternative forms of remuneration

Beyond direct director remuneration, several complementary mechanisms can further reduce your overall tax bill.

Group insurance (supplementary pension)

Group insurance is an excellent tax optimisation tool:

• The premium paid by the company is deductible for corporate tax purposes
• The premium is subject to a 4.4% tax and a 3.55% INAMI contribution
• The capital built up is taxed at a favourable rate of 10% (plus municipal tax) when paid out, at the legal retirement age
• The 80% rule caps the deductible amount: the statutory pension plus the supplementary pension cannot exceed 80% of the last normal gross annual remuneration

Example: a director with gross remuneration of EUR 45,000 and an estimated statutory pension of EUR 15,000/year can pay a group insurance premium building a supplementary pension of up to EUR 36,000/year (80% of EUR 45,000) minus EUR 15,000, giving a maximum supplementary pension of EUR 21,000/year.

The EIP (Individual Pension Commitment)

The EIP (Engagement Individuel de Pension) is the individual version of group insurance, aimed specifically at self-employed company directors. The rules mirror those of group insurance: the 80% rule, 4.4% tax, 10% taxation.

The PLCI (voluntary supplementary pension for the self-employed)

The PLCI is a pension savings product specifically for the self-employed:

• Premium deductible as a social security expense
• Maximum premium in 2026: around EUR 3,965.77 (standard PLCI) or EUR 4,562.63 (social PLCI)
• The social PLCI also provides incapacity-for-work cover
• Capital taxed at 10% (plus municipal tax) at retirement

The current account

The director can lend money to their company via a credit current account. The company pays interest on this loan:

• The interest rate must be in line with the market (art. 55 CIR 92 caps the deductible rate)
• The interest is taxable for the director at the 30% withholding tax rate (final)
• The interest is deductible for the company (within the limits of art. 55 CIR 92)

Warning: if the interest rate exceeds the market rate, or if the loan amount is excessive, the excess portion of the interest is reclassified as dividends (art. 18 CIR 92).

Copyright income

Since the law of 16 December 2022, the favourable tax regime for copyright income has been reformed. Copyright income benefits from an advantageous tax rate:

• 15% withholding tax (after deducting flat-rate expenses of 50% on the first bracket and 25% on the second)
• Annual ceiling: around EUR 72,560 (2026 indexed amount) of gross income
• The regime is reserved for holders of a certificate from the relevant sector body, or creators of original works protected by copyright

Relevant sectors: software developers (original source code), architects, graphic designers, photographers, writers, musicians, etc.

Overall optimisation: the step-by-step method

Use this method to build an optimal director remuneration package step by step.

Step 1: Pay yourself remuneration of at least EUR 45,000

Setting your director remuneration at this level allows you to:

• Benefit from the reduced 20% corporate tax rate (instead of 25%)
• Avoid the 5.1% separate contribution
• Build up statutory pension rights

Step 2: Maximise group insurance / EIP

Calculate the maximum deductible amount while respecting the 80% rule.

Step 3: Take out a PLCI (and social PLCI)

Maximum deduction as a social security expense, with incapacity-for-work cover as a bonus.

Step 4: Optimise benefits in kind

• A fully electric company car (maximum deductibility + minimal benefit-in-kind value)
• Company mobile phone, internet and computer

Step 5: Make use of copyright income (if applicable)

If your business generates works protected by copyright.

Step 6: Distribute dividends (VVPR-bis if possible)

Any profit surplus remaining after the previous steps can be distributed as dividends, preferably under the VVPR-bis regime.

Step 7: Build up reserves

Keep a sufficient cash reserve within the company (the CSA's double test requires this anyway for dividend distributions).

The double test for dividend distributions

The CSA requires a double test before any dividend distribution:

The net asset test (art. 5:141 CSA)

The company's net assets cannot become negative after the distribution. Net assets are defined as total assets less provisions and liabilities.

The liquidity test (art. 5:142 CSA)

The company must remain able to pay its debts falling due within 12 months of the distribution. The management body must draw up a special report confirming that the company meets the liquidity test.

Penalty: if a distribution is made in breach of the double test, the directors are jointly and severally liable to the company and third parties (art. 5:138 CSA).

Common mistakes and points to watch

Even experienced directors make costly mistakes when planning director remuneration.

1. Not paying yourself any remuneration

Risk: the 5.1% separate contribution, loss of the reduced 20% corporate tax rate, and no statutory pension rights built up.

2. Paying yourself too much remuneration

Risk: 50% taxation (plus social contributions and municipal surcharges) on the top bracket. It is often more advantageous to distribute the excess as dividends.

3. Distributing dividends without meeting the double test

Risk: personal liability for the director.

4. Ignoring advance tax payments

As a company director, you must make advance tax payments (versements anticipés) to avoid a tax surcharge (art. 157-168 CIR 92). The deadlines are 10 April, 10 July, 10 October and 20 December.

5. Not documenting remuneration decisions

Every remuneration or dividend distribution decision must be documented in the minutes of a general meeting or board meeting.

Conclusion

Structuring the remuneration of an SRL director (administrateur) in Belgium is a complex tax optimisation exercise — but a highly rewarding one. By intelligently combining director remuneration (a minimum of EUR 45,000), dividends (ideally under VVPR-bis at 15%), group insurance/EIP, the PLCI, optimised benefits in kind (an electric car) and, where applicable, copyright income, you can significantly and entirely legally reduce your overall tax burden.

Do not attempt this exercise alone: consult a certified accountant (ITAA-approved) or a tax adviser, who can model different scenarios tailored to your personal situation and that of your company.

---

This article was written by the Espero-Soft team for the blog dedicated to entrepreneurs in Belgium. For personalised advice, consult a certified accountant (ITAA-approved) or a tax adviser.