The laws around the Belgian transaction tax ("beurstaks" or "taxe boursière" or TOB) are complicated and confusing. To make it worse, the laws change regularly. Even brokers are confused and charge a different tax rate for the same fund.

This how-to provides a step-by-step guide for figuring out the Belgian transaction tax of any ETF.

Disclaimer: We attempt to keep this article up-to-date with the latest laws around the TOB. But we cannot guarantee this to be the case when you're reading this. Check at the top when the how-to was last updated. Also, we are not professional tax advisors.  Always do your own research or seek external advice, especially if the outcome can affect your financial situation.

Step-by-step guide

You need to answer five questions to determine the TOB of an ETF:

  1. Is it really an ETF?
  2. Is it registered in the European Economic Area?
  3. Is it registered in Belgium?
  4. Is any compartment of the fund registered in Belgium?
  5. Is it distributing or accumulating?

Let's determine how we can answer each question.

1) Is it an ETF?

The most common ways to invest in a fund in Belgium are through:

  • Mutual funds. These are commonly called SICAV in French or BEVEK in Dutch.
  • ETFs.

The main difference is that ETFs are traded on an exchange (hence their name "Exchange-Traded Fund"). In contrast, mutual funds are bought directly from the fund provider, without an exchange coming in between.

You can search for a fund's ISIN code in your broker's search functionality to check whether a fund is an ETF. Or, if the fund is on justETF, then it's an ETF.

Continue reading if the fund is an ETF.

Yes, IE00B4L5Y983 is an ETF because it's on justETF

2) Registered in the European Economic Area?

When we've determined that we're dealing with an ETF, we need to answer whether the fund is registered within the European Economic Area. The EEA consists of all EU member states as well as Iceland, Liechtenstein and Norway.

Fund providers list the countries where a fund is registered on their website. The easiest way to get to the right page is through Google. Type in the ISIN of the fund and go to the search result on the fund provider's website.

Finding the official page on the iShares website for the fund IE00B4L5Y983

On the page of the fund provider, we see the countries that the fund is registered in. Let's look at some examples.

iShares Core MSCI World (IE00B4L5Y983)

On the iShares website we can see that the fund is registered in several countries within the EEA.


iShares Core SPI (CH0237935652)

The fund is domiciled in Switzerland, which you can tell because the ISIN starts with "CH". But on the iShares website we see it is also registered in Liechtenstein. So it is registered in the EEA, as Liechtenstein is part of the EEA.

Vanguard Total Stock Market ETF (US9229087690)

American funds (the ISIN starts with "US") are not registered in the EEA.

Not registered in the EEA?

The transaction tax is 0.35% at purchase and 0.35% at sale. You can stop the how-to.

Registered in the EEA?

Continue to the next step.

3) Registered in Belgium?

We can use the list of countries from the previous step to determine if a fund is registered in Belgium.

Not registered in the Belgium?

Continue to the next step.

Registered in Belgium?

You may skip to step 5.

4) Is any compartment of the fund registered in Belgium?

A fund can have several compartments, for instance to provide accumulating and distributing versions of the fund, or to offer it in multiple currencies. Each compartment gets its own ISIN code and the fund provider can choose to register compartments in different countries. So the distributing compartment of a fund can be registered in Belgium whereas its accumulating compartment is not.

As soon as one of the compartments of a fund is registered in Belgium, the Belgian tax authorities consider all compartments to be registered in Belgium. This has significant implications for the TOB rate. Because if a distributing compartment of a fund is registered in Belgium but its accumulating compartment is not, the accumulating fund will still be taxed as if it was registered in Belgium. And the TOB rate is then 1.32% instead of 0.12%, which is an 11-fold difference.

The FSMA, the Belgian financial regulator, maintains a list of all foreign funds that are registered in Belgium. You can download the spreadsheet here. Unfortunately, the list does not consist of ISIN codes. Instead, to check whether the fund is on the list, we have to rely on:

  • The name of the fund (columns "Compartment French official name"/"Compartment Dutch official name" in the spreadsheet)
  • The issuing company (columns "CIS French official name"/"CIS Dutch official name" and "CIS Legal form")

The fund is registered in Belgium if there's an entry in the spreadsheet where the names match, and the issuing company matches exactly. This sounds tedious, and it is. It will become clearer in the examples below, where we calculated the TOB for some popular ETFs.

But first, let's move on to the last but easy step: determine whether the fund is accumulating or distributing.

The list by the FSMA can be found on https://www.fsma.be/nl/instellingen-voor-collectieve-belegging-icb (Dutch) or https://www.fsma.be/fr/organismes-de-placement-collectif-opc (French)


5) Distributing or accumulating?

The Belgian authorities charge a different TOB rate for funds that distribute dividends (distributing funds) and those directly reinvest them (accumulating funds). You can check whether a fund is accumulating or distributing on justETF, or on the website of the fund provider.

The fund or one of its compartments is registered in Belgium

  • Distributing fund: the TOB is 0.12% at purchase and 0.12% at sale
  • Accumulating fund: the TOB is 1.32% at purchase and 1.32% at sale

The fund or one of its compartments is NOT registered in Belgium

  • Distributing fund: the TOB is 0.12% at purchase and 0.12% at sale
  • Accumulating fund: the TOB is 0.12% at purchase and 0.12% at sale

Visual guide

The chart below makes it clearer:

Belgian transaction tax for popular ETFs

To illustrate, we followed the guide to calculate the TOB for three popular ETFs:

  • VWCE (Vanguard FTSE All-World)
  • IWDA (iShares Core MSCI World)
  • IESE (iShares MSCI Europe SRI)

VWCE (Vanguard FTSE All-World)

Is it an ETF? Yes

It's on justETF.

Is it registered in the European Economic Area? Yes

The fund is registered in several countries within the EEA:

VWCE is registered in Belgium according to the Vanguard website.

Is it registered in Belgium? Yes

From the same list, we know that the fund is registered in Belgium.

Distributing or accumulating? Accumulating

On justETF we see that the fund is accumulating.

Conclusion: TOB is 1.32% at purchase and 1.32% at sale

IWDA (iShares Core MSCI World)

Is it registered in the European Economic Area? Yes

The fund is registered in several countries within the EEA.

IWDA is registered in several countries within the EEA (from iShares website).

Is it registered in Belgium? No

Belgium is not on the list of registered countries.

Is any compartment of the fund registered in Belgium? No

We have to look at the spreadsheet by the FSMA. There is a fund named "iShares Msci World Ucits Etf":

The list by the FSMA has an entry for "iShares Msci World Ucits Etf"

We also see that the fund provider is "iShares PLC". But when we check the fund on iShares, we see that the fund provider doesn't match: IWDA is managed by "iShares III PLC", which is a different legal entity than "iShares PLC". Furthermore, all of the variants of IWDA, EUR Hedged (Distributing) or GBP Hedged (Distributing), are managed by "iShares III PLC".

We conclude that no compartment of IWDA is registered in Belgium.

IWDA on the iShares website

Distributing or accumulating? Accumulating

On justETF we see that the fund is accumulating.

Conclusion: TOB is 0.12% at purchase and 0.12% at sale

IESE (iShares MSCI Europe SRI)

Is it registered in the European Economic Area? Yes

See on the iShares website.

Is it registered in Belgium? No

Belgium is not on the list of registered countries.

Is any compartment of the fund registered in Belgium? Yes

There's an entry with a matching name. And the issuing company on the FSMA spreadsheet, "iShares II PLC", matches the issuing company on the iShares website.

There's a compartment of the iShares MSCI Europe SRI fund registered in Belgium.

When we look at the iShares website for its distributing compartment IE00BGDPWW94 (see here), we can actually confirm that it is registered in Belgium.

Distributing or accumulating? Accumulating

The fund is accumulating.

Conclusion: TOB is 1.32% at purchase and 1.32% at sale

Taking into account the transaction tax when setting up your portfolio

Taking care of the transaction tax is a downside of managing your own investments and buying ETFs directly. You need to choose the ETFs such that your portfolio:

  • Is diversified. VWCE provides great diversification in a single fund but has a 1.32% transaction tax. We calculated that the impact of the high TOB on the long-term return is not negligible.
  • You're not over-spending on broker fees. Brokers charge a commission for every transaction. So broker fees increase when you have more funds in your portfolio. A simpler portfolio is therefore preferred. You need to take this into account if you want to replace VWCE, which has a high transaction tax, with alternatives that have a lower TOB but will result in higher broker fees.
  • Is future-proof. Suppose you have a large investment in an ETF, accumulated after many years of investing. You will be very unhappy if its transaction tax were to increase drastically.

Other taxes applicable to ETFs

To make matters more complicated, the transaction tax isn't the only relevant tax when investing in ETFs. The other taxes are:

  • Tax on dividends
  • Reynders tax, or tax on capital gains for bonds
  • Tax on investment accounts exceeding €1,000,000

Learn more about all the taxes applicable to ETFs

Not having to worry about the transaction tax

Investment apps are a way to passively invest in ETFs while not having to worry about the transaction tax. At Curvo, all taxes are taken care of. Also, each Curvo portfolio is globally diversified and has already been optimised for cost so you don't have to calculate the trade-offs yourself. Find out how Curvo works

Conclusion

The rules around the Belgian transaction tax for ETFs are complicated, but fortunately there is a method to figure it out. However, the transaction tax adds another variable to take into account when optimising your portfolio. This makes it harder to find the right portfolio allocation that will give you success over the long term.

Using an investment app like Curvo lets you invest passively in ETFs without having to worry about taxes.

Finally, we would like to reiterate that we aim to keep this how-to up-to-date with the latest tax situation, but we cannot guarantee this. So always do your own research or seek external advice if the outcome of the transaction tax can have a big impact on your financial situation.

Thank you to Tim Nijsmans from Vermogensgids for his feedback on this how-to.