The Walloon decree of 5 December 2024 will transform Wallonia into one of the most attractive regions in Europe for the transfer of property assets. From 1 January 2028, direct-line inheritance tax will drop from 24–30% to a maximum of 12–15%. For property managers who advise their clients on estate planning, this is a reform to integrate into every wealth planning conversation.
What are the new Wallonia inheritance tax rates from 2028?
From 1 January 2028, the maximum rate of direct-line inheritance tax (from parents to children) in Wallonia will be halved, dropping from 24–30% to 12–15% for amounts above EUR 250,000. For transfers outside the direct line (between unrelated parties or third parties), the maximum rate drops from 80% to 40%. This reform, stemming from the decree of 5 December 2024, positions Wallonia as the most competitive Belgian region for inheritance tax.
The European comparison that changes everything
To understand the scale of the reform, compare the inheritance tax rates applicable to a property portfolio transferred to a single child across different jurisdictions.
| Region / Country | Max rate direct line (> EUR 250,000) | Max rate outside direct line |
|---|---|---|
| Belgium — Brussels | 24% to 30% | 80% |
| Belgium — Flanders | 27% | 55% |
| Belgium — Wallonia (2026–2027) | 24% to 30% | 80% |
| Belgium — Wallonia (2028+) | 12% to 15% | 40% |
| France | 20% to 45% | 60% |
| Luxembourg | 0% | 15% to 60% |
| Netherlands | 20% | 40% |
| Italy | 4% | 8% |
From 2028, the maximum Wallonia rate in the direct line will be:
- Half of the Brussels rate
- One third of the maximum French rate
- Comparable to the Netherlands, which is widely considered a low-tax country
This reform is particularly significant for larger property portfolios — those exceeding EUR 500,000 — where the tax burden is heaviest.
The 7 estate planning strategies to know
The Walloon reform comes with a toolkit of legal strategies that property owners and their advisers can use to optimise the transfer. Here are the main ones, with their applicability and advantages.
1. Do not act in haste
The first strategy is often to wait. Below EUR 250,000 transferred per child, inheritance tax rates remain reasonable across all three Belgian regions (7%–10%). There is no need to rush into complex structures for modest portfolios — the tax benefit does not always justify the legal complexity and associated costs.
Tip for property managers: before advising on advanced strategies, assess the net value of your client's property portfolio. If each child inherits less than EUR 250,000, inheritance planning is less urgent.
2. Move to Wallonia to benefit from the new rates
The decree of 5 December 2024 introduced an important simplification: the requirement to have been resident in Wallonia for 5 years has been removed. Previously, you had to demonstrate a Walloon domicile for at least 5 years before death for Walloon rates to apply.
Now it is sufficient for the deceased to be domiciled in Wallonia at the time of death for Walloon rates to apply to the entire estate. This considerably simplifies planning for property owners domiciled in Brussels who wish to benefit from Walloon rates.
Important: the change of domicile must be genuine (actual residence), not fictitious. The tax authorities verify the reality of domicile.
3. Protect the spouse with a mixed marriage contract
A mixed marriage contract combines two regimes:
- Separation of assets as the base regime (each spouse retains ownership of what they bring in and acquire)
- Limited accessory community for shared savings
This combination allows, via an appropriate will, the primary residence to pass to the surviving spouse without inheritance tax. The property remains outside the estate for the children, who only inherit after the death of the last surviving parent.
Tax advantage: deferral of inheritance taxation by one generation, with the possibility that rates may be even more favourable at the time of the second death.
4. Generation skipping: renouncing in favour of grandchildren
Generation skipping is now possible in all three Belgian regions. A child renounces all or part of their inheritance, allowing grandchildren to inherit directly. Each grandchild then benefits from their own EUR 250,000 band at the reduced rate.
Illustration for an estate of EUR 500,000 transferred in Wallonia:
| Scenario | Inheritance tax 2025–2027 | Inheritance tax 2028+ |
|---|---|---|
| 1 child inherits alone | EUR 86,625 | EUR 42,250 |
| Renunciation: 2 grandchildren | EUR 53,250 | EUR 25,500 |
Generation skipping saves up to EUR 16,750 compared to a direct transfer, even under the new Walloon 2028 rates.
Condition: renunciation must be total or partial according to the rules of the Civil Code. A notary is essential to formalise the operation.
5. The fidei-commis in the will
This estate planning technique is particularly suited to families with several children where dispersal of assets is a concern. The principle: the testator bequeaths to a first beneficiary (for example, a child) with the obligation to pass on what remains to a designated second beneficiary (for example, the first beneficiary's children).
Practical application: a parent bequeaths to three children, and provides in the will that if one child dies without descendants, their share passes to the other children. Taxation then applies in the direct line (parent to child), not between siblings — avoiding a rate of 30%–65% depending on the region.
6. The duo legacy: a Brussels and Wallonia technique
The duo legacy is an estate planning technique applicable in Brussels and Wallonia that allows the prohibitive rates on transfers outside the direct line (80% before 2028, 40% after) to be circumvented.
How it works:
- The testator appoints a non-profit organisation as universal legatee
- The organisation takes on the entire inheritance tax liability
- The organisation passes approximately 50% net to the persons designated in the will (friends, nephews, etc.)
Comparison for a legacy of EUR 100,000 to a friend:
- Without duo legacy: the friend receives approximately EUR 20,000 (after 80% tax)
- With duo legacy: the friend receives approximately EUR 50,000
The Walloon 2028 reform reduces the advantage of the duo legacy for transfers between unrelated parties (the rate drops from 80% to 40%), but the technique remains relevant for large legacies.
7. Property donations every 3 years
The clawback period for manual gifts (cash, securities) has been extended to 5 years in Belgium. But the interval between two property donations remains 3 years. It is therefore possible to "slice up" a property portfolio into successive donations to benefit from the lowest rates on each tranche.
Example for a building worth EUR 600,000:
- Donation 1 (2026): EUR 200,000 — rate applicable to this tranche
- Donation 2 (2029): EUR 200,000 — fresh allowance, low rate on the initial tranche
- Donation 3 (2032): EUR 200,000 — same advantage
This strategy requires long-term planning and a notary, but it can significantly reduce the overall tax burden compared to a transfer at the time of death.
What property managers need to retain
The Walloon inheritance reform will accelerate property portfolio transfers in the coming years. Property owners who had deferred their inheritance planning will want to act before 2028 to position themselves favourably, or wait until 2028 to benefit from the new rates.
Warning signs to monitor in your portfolio
- Property owners over 70 with a portfolio above EUR 500,000
- Assets transferred outside the direct line (nephews, friends, associations)
- Property owners domiciled in Brussels with assets in Wallonia
- Ongoing estates involving multiple heirs
How Seido helps you
Supporting your clients through their transfer projects starts with an accurate knowledge of their portfolio: estimated value of each property, maintenance and works history, annual charges, current leases. This information is essential for notaries and tax advisers to propose the right strategies.
With Seido, you have a complete view of each property: its maintenance history, its documents, its leases, and its value — valuable information for supporting your clients in their transfer projects. Discover Seido →
This article is part of Property Essentials #1 — January 2026. Also read: Brussels winter moratorium: the landlord compensation fund most owners ignore.
Sources and references
- Decree of 5 December 2024 reforming Walloon taxation, Belgian Official Gazette, 2024
- Reform of inheritance and gift taxes in Wallonia: what changes in 2028, Notaire.be, December 2024
- Reduction of registration, inheritance and gift duties, Wallonie.be
- Overview of inheritance tax regimes in Europe, La finance pour tous, 2024
- Inheritance tax in OECD countries, OECD, 2024