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 11/09/2026 | Reading time: 4 minutes 

 

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Ralph Verduyn

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Since 8 August 2025, it has once again been possible in Belgium to regularise income and capital that were not declared in the past. With the introduction of EBA quinquies, the fifth round of regularisation, taxpayers once again have the opportunity to rectify their tax situation and obtain legal certainty.

 

 

 

For crypto investors, this scheme is particularly relevant, as banks are increasingly asking questions during cash-outs about the origin of the funds used to finance the initial investment.

## What is EBA quinquies?

EBA quinquies is the new Belgian regularisation procedure, introduced by the Programme Act of 18 July 2025.

The scheme allows previously undeclared income and capital whose tax origin cannot be demonstrated to be voluntarily declared.

In concrete terms, this may include, for example, investments made with funds for which it cannot be proven that they have undergone the appropriate tax treatment. This includes so-called “black” income or funds that do not originate from a regular domestic bank account.

## Why is this scheme relevant for crypto investors?

Many Belgian crypto investors made their first investments with funds whose origin is now difficult to reconstruct.

These are often investments made many years ago, when crypto was still a niche phenomenon and received little attention from banks and tax authorities. However, when these crypto assets now represent significant value and are eventually converted into fiat currency, the bank involved increasingly raises questions about the origin of the initial investment.

Due to the stricter anti-money laundering policies of banks and financial institutions, it has become particularly difficult to simply transfer substantial amounts originating from crypto to a Belgian bank account. Banks are increasingly requesting supporting documents demonstrating that the funds concerned have a legitimate tax origin.

There is also a criminal law risk. Even when certain income or capital is time-barred for tax purposes, prosecution for money laundering may still be possible.

## What can be regularised?

EBA quinquies applies exclusively to federal taxes.

In practice, the following income and capital, among others, can be regularised:

- taxable capital gains on crypto assets, insofar as they qualify as miscellaneous income or professional income;
- investment income, such as staking income;
- undeclared corporate profits;
- unpaid VAT;
- capital that is time-barred for tax purposes and whose origin cannot be demonstrated.

For crypto investors, the issue often centres on whether it can be demonstrated that the funds used to finance the original investment underwent the correct tax treatment.

## How much does regularisation cost?

The cost depends on the nature of the amounts to be regularised.

For income that is not time-barred, the normal tax rate applies, increased by an additional levy of 30%.

For capital that is time-barred for tax purposes, in principle capital older than seven years, the regularisation levy amounts to 45%.

When calculating the cost of regularisation, no account is taken of tax reductions, tax credits or advance tax payments, meaning that the final cost can be significant.

## How does the procedure work?

The regularisation procedure is handled through the Regularisation Contact Point of the FPS Finance.

In concrete terms, the procedure consists of the following steps:

### Step 1: preparing the file

The file includes, among other things:

- a description of the origin and amount of the income or capital;
- an explanation of how and when the crypto assets were acquired;
- an overview of the accounts and wallets concerned;
- a so-called fraud scheme setting out the situation.

### Step 2: review by the Contact Point

The Contact Point reviews the file and determines the regularisation levy due.

### Step 3: payment

The levy due must be paid within fifteen days of notification.

### Step 4: regularisation certificate

After payment, the taxpayer receives a regularisation certificate.

This certificate provides both tax and criminal immunity for the regularised amounts.

## Conclusion

With EBA quinquies, Belgium once again has a permanent regularisation system.

For crypto investors, this scheme may be relevant when the origin of the funds used to finance the initial crypto investment can no longer be demonstrated or when these funds never underwent the correct tax treatment.

In a context of stricter anti-money laundering controls, increasing international exchange of information and critical questions during cash-outs, a timely analysis of your file can remove a great deal of uncertainty.

Do you have questions about EBA quinquies or would you like to determine whether regularisation is appropriate in your situation?

Do not hesitate to contact one of our specialists. Together, we will assess which approach is most appropriate for your case.

 

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