Tax on Salary and Bonuses Paid in Crypto in Belgium

Belgium is home to a growing number of individuals active in the crypto ecosystem. This includes not only developers, but also professionals in legal, compliance, finance, marketing and management roles. Both employees and self-employed individuals increasingly work for blockchain projects, crypto platforms and Web3 initiatives, often within international structures.

In recent months, we have increasingly been asked whether Belgian tax is due on salary or bonuses paid in crypto. Within the crypto sector, it has become common practice for part of the remuneration to be paid not in euros, but in crypto. In many cases, this concerns a monthly or annual bonus paid in the coin or token of the project for which the individual works. This practice raises important tax questions.

Let us be clear from the outset: the fact that remuneration is paid in crypto does not mean that it is tax-free. In many cases, such remuneration is effectively subject to Belgian tax. In this article, we take a closer look at the key tax considerations when receiving salary or bonuses in crypto.

Scope and Assumptions of This Article

This article explicitly proceeds on the assumption that the tokens or coins are received as consideration for work performed or services rendered. The crypto remuneration therefore forms an integral part of the salary or professional fee.

Situations in which tokens are granted free of charge, without a direct link to professional services, or where an argument could be made that there is a gratuitous acquisition, fall outside the scope of this analysis and are not discussed here.

This article focuses exclusively on the tax treatment at the level of the employee or the self-employed individual. Social security contributions and employer-side obligations fall outside the scope of this discussion.

For employees, it should nevertheless be noted that the payment of salary or bonuses in crypto is not without labour-law risks. Under the Belgian Wage Protection Act (Article 6 of the Act of 12 April 1965 on the protection of employees’ remuneration), salary must be paid in legal tender. A payment purely in crypto may therefore be legally problematic and could give rise to disputes regarding unpaid salary. This does not alter the fact that, once crypto is effectively granted as remuneration for work performed, it is taxable income for tax purposes. This article focuses on that tax reality.

Is Salary or a Bonus Paid in Crypto Taxable in Belgium?

Where crypto or tokens are granted as remuneration for work or services, they generally qualify as taxable professional income, both for employees and for self-employed individuals.

A common misconception is that a crypto bonus would only become taxable when converted into euros. This is incorrect. Taxation arises at the moment the tokens are definitively vested and the beneficiary can effectively dispose of them.

The absence of salary slips or invoices does not affect this taxability. Even in the absence of formal documentation, such income must be reported in the personal income tax return.

Taxation of Crypto Bonuses and Token-Based Compensation

In practice, crypto remuneration is rarely granted immediately and unconditionally. It is often structured through contractual arrangements that spread the grant over time or make it conditional upon certain events. This has a direct impact on the moment at which the remuneration becomes taxable.

RCU and RTU Structures: When Does Taxation Arise?

Within the crypto sector, remuneration is often structured through so-called RCU’s (Restricted Crypto Units) or RTU’s (Restricted Token Units). These instruments grant a right to receive crypto or tokens, typically subject to vesting schedules, lock-ups or performance conditions.

As long as the beneficiary does not have an unconditional right and no effective control over the tokens, no taxable event generally arises. Taxation only occurs once the vesting conditions are met and the employee, self-employed individual or company can definitively dispose of the tokens.

That moment determines both the valuation and the reporting of the income for tax purposes.

Working for Crypto Projects via a Belgian Intermediary (EOR/PEO-providers)

In practice, many individuals active in the crypto sector do not work directly for the foreign blockchain project, but through a Belgian intermediary that formally acts as employer (EOR/PEO-providers). The crypto bonus is often granted directly by the foreign project, outside the intermediary’s traditional payroll or invoicing flow.

Our experience shows that such Belgian intermediaries are often unaware, or insufficiently aware, of the token grants. Salary slips are not adjusted, invoices are not issued, and no documentation is prepared that could serve as a basis for correct tax reporting. As a result, there is often no paper trail, other than the receipt of the crypto or tokens in a wallet.

This lack of documentation does not affect the tax treatment. In most cases, such crypto income qualifies as normal remuneration for services and must be reported as professional income.

How Should a Crypto Bonus Be Reported for Tax Purposes?

Where official documentation is lacking, the responsibility lies with the taxpayer to determine the taxable base. That base corresponds to the value of the crypto received at the moment of definitive vesting.

In practice, the taxable amount is determined by multiplying the number of tokens or coins received by their value at the moment of vesting. It is advisable to use official and verifiable exchange rates, to document them carefully and to apply them consistently. Using a fixed and recognised pricing source reduces the risk of disputes in the event of a tax audit.

For individuals who receive crypto on a regular basis, specialised software such as Koinly, CoinTracking or Summ may be useful. For a one-off annual bonus, a manual calculation may suffice, provided it is adequately substantiated.

Freelancers Paid in Crypto: VAT Treatment

For self-employed individuals, payment in crypto does not in itself alter the VAT qualification. Where tokens or crypto are received as consideration for services, this generally constitutes a supply of services for consideration. The taxable amount is the value in euros of the tokens or crypto at the moment they are granted or received.

In practice, blockchain projects are often established outside Belgium. Where services are supplied to a customer within the European Union, the VAT reverse-charge mechanism generally applies and must be explicitly mentioned on the invoice. Where the project is established outside the European Union, the service falls outside the scope of EU VAT, but a proper invoice is still required.

Consequences of Failing to Report Crypto Income

Failing to report crypto income can have significant consequences. When converting crypto into euros and transferring funds to a Belgian bank account, banks increasingly ask questions about the origin of the funds and whether they have been properly taxed. Without a tax return or supporting documentation, this may lead to account blocks or additional scrutiny.

In addition, there is a risk of a tax audit. Where the tax authorities determine that crypto income linked to professional activities has not been reported, they may tax it retroactively, often with tax increases and late-payment interest.

Volatility, Value Loss and Tax Consequences

Crypto and tokens are often volatile. Taxation takes place at the moment of receipt or definitive vesting, not at the moment of conversion into euros. If the value of the tokens subsequently decreases, the tax remains due on the basis of the original value. Such subsequent value loss has no impact on the taxation of the professional income itself.

By way of illustration, assume that an employee or self-employed individual receives a bonus of 1,000 tokens with a value of EUR 100 per token at the moment of vesting. The taxable base amounts to EUR 100,000.

If, by the time the tax becomes payable, the value of those tokens drops to EUR 10 per token, the tokens are then worth only EUR 10,000, while tax remains due on the original taxable base of EUR 100,000.

Assuming a marginal personal income tax rate of 50%, this results in a tax burden of EUR 50,000 on tokens that are then worth only EUR 10,000.

Capital Gains on Received Tokens or Crypto: Distinction from Remuneration

It is essential to distinguish between, on the one hand, the taxation of crypto as remuneration for professional services and, on the other hand, any subsequent capital gain realised upon the sale of that crypto.

The taxation of the remuneration arises at the moment of receipt or vesting, as discussed above. The analysis below concerns only the capital gain, being the difference between the value of the tokens at vesting and their value at the time of sale. This capital gain must be assessed separately from the original professional income.

Regime up to and Including Tax Year 2025

Up to and including tax year 2025, capital gains on crypto realised by private individuals are in principle tax-exempt where they fall within the normal management of private assets. If the tax authorities consider the transactions to be speculative, the capital gain may be taxed as miscellaneous income at a rate of 33% (plus municipal surcharges). In exceptional cases, requalification as professional income may even be envisaged.

The mere fact that the tokens were originally received as remuneration does not automatically imply that any subsequent capital gain must again be treated as professional or speculative income. This requires a separate factual assessment.

Regime from Tax Year 2026

From tax year 2026 onwards, Belgium will introduce a general capital gains tax on crypto-assets. In principle, realised capital gains will be taxed at 10%, with an annual exemption of EUR 10,000, of which up to EUR 1,000 per year can be carried forward, allowing the exemption to increase to a maximum of EUR 15,000 over a five-year period. Capital gains relating to value increases realised before 1 January 2026 remain outside the scope of this tax, subject to specific exceptions.

Even under this new regime, a factual analysis remains crucial: where the tax authorities consider the activity to be speculative, the capital gain may still be taxed as miscellaneous income at 33%. For a more detailed discussion of the new crypto capital gains tax and the applicable transitional rules, we refer to our separate article on this topic.

No Automatic Requalification as Professional Income

In our view, receiving tokens as remuneration for professional services does not automatically lead to the conclusion that any subsequent capital gain is professional or speculative in nature. This is particularly the case where the taxpayer does not engage in active crypto trading or investment activities.

By way of example, consider an individual working in the legal or HR department of a blockchain project, who does not otherwise invest in crypto and receives a token bonus only once per year. In such circumstances, it can be argued that any capital gain realised upon sale falls within the normal management of private assets.

Increasing Transparency: DAC8 and Crypto Reporting

With the introduction of DAC8, the automatic exchange of information on crypto transactions will increase significantly. From 2026 onwards, crypto platforms will systematically report information to the tax authorities. The argument that crypto income was not reported due to a lack of salary slips or documentation will therefore become increasingly difficult to sustain. More information on the data to be exchanged under DAC8 can be found here.

Practical example: crypto bonus in a blockchain project

Consider an individual who, in 2025, is employed by a blockchain project. Under the terms of his contractual objectives, he becomes entitled to a bonus of 1,000 tokens if certain performance targets are met. On 10 January 2026, the tokens are definitively granted and received by the individual. At that time, the market value of the tokens, according to CoinMarketCap, is EUR 10 per token.

At that moment, taxable professional income of EUR 10,000 arises. For employees, this amount must be reported as employment income (code 1250 in the personal income tax return). For self-employed individuals, it qualifies as profits or gains (code 1600).

Assume that the tokens are subsequently sold on 20 January 2026 at a value of EUR 11 per token. The realised capital gain amounts to EUR 1,000. This capital gain must be assessed separately from the professional income. Under certain circumstances. It can be argued that such a gain falls within the normal management of private assets. As from income year 2026, realised capital gains on crypto-assets are, in principle, subject to a 10% capital gains tax under the newly announced Belgian regime, subject to an annual exemption of EUR 10,000, which can be built up to EUR 15,000 over a five-year period.

At the time of writing, the relevant legislation has not yet been formally adopted. However, based on the announced policy framework, it is expected that the new regime will apply to capital gains realised as from 1 January 2026, subject to the final wording of the law and any transitional provisions.

If, on the other hand, the value of the tokens decreases to EUR 9 per token, the taxable professional income remains EUR 10,000, notwithstanding the subsequent loss in value. This illustrates the liquidity and volatility risk inherent in remuneration paid in crypto-assets.

For self-employed individuals, it is furthermore advisable to document this remuneration by issuing an invoice with the appropriate VAT wording. Although arguments may exist in certain structures for not issuing an invoice, proper invoicing significantly reduces the risk of disputes in the context of tax audits.

Conclusion: Crypto Bonuses and Remuneration Are Taxable in Belgium

Although payment of remuneration or bonuses in crypto has become common practice within the crypto sector, it remains subject to the traditional principles of Belgian tax law. Where tokens or crypto are granted as consideration for work or services, they generally constitute taxable professional income, regardless of the form of payment and regardless of whether formal salary slips or invoices exist.

A clear distinction must also be made between taxation of the remuneration at the time of receipt and the subsequent tax treatment of any capital gains. In a context of significant volatility, a lack of prior analysis may lead to substantial tax and liquidity risks. The fact that tokens were initially received in a professional context does not automatically imply that later capital gains will also be treated as professional or speculative income. That assessment remains largely fact-dependent.

Finally, increasing transparency through international reporting obligations such as DAC8 will further limit the scope for unreported crypto income. Individuals receiving remuneration in crypto would therefore be well advised to analyse and report such income correctly and in a timely manner, rather than relying on assumptions about supposed tax exemptions.

Frequently Asked Questions – Salary and bonuses paid in crypto

Is a salary or bonus paid in crypto taxable in Belgium?

Yes. If crypto or tokens are granted as consideration for work or services, they are generally taxable as professional income, regardless of the form of payment.

When does taxation arise: upon conversion to euros or upon receipt?

Taxation arises when the tokens are definitively vested and the beneficiary can effectively dispose of them, not when they are converted into euros.

Is it legally allowed to pay salary or bonuses in crypto in Belgium?

Belgian labour law generally requires salary to be paid in a legal means of payment, and it is widely accepted that a pure payment of salary or bonuses in crypto is legally problematic.This does not prevent such arrangements from occurring in practice. Importantly, the potential labour law issues do not affect the tax treatment: once crypto is effectively granted as remuneration, it is taxable as income.

How do I determine the taxable amount if there are no payslips or invoices?

The taxable base corresponds to the number of tokens multiplied by their euro value at the moment of definitive vesting, using a verifiable and consistently applied price source.

Do vesting structures such as RCU or RTU delay taxation?

Generally, yes. As long as there is no unconditional right and no effective control over the tokens, taxation is usually deferred until vesting occurs.

What if the value of the tokens drops after taxation?

A subsequent decrease in value does not reduce the taxable professional income, which can create a significant liquidity risk.

Are capital gains on received tokens taxed separately?

Yes. The taxation of the remuneration at vesting is separate from any later capital gain realised upon sale, which must be assessed independently.

How are crypto capital gains treated as from income year 2026?

As from income year 2026, realised capital gains on crypto-assets are expected to be subject to a 10% capital gains tax, subject to an annual exemption of EUR 10,000, of which up to EUR 1,000 per year can be carried forward, allowing the exemption to increase to a maximum of EUR 15,000 over five years, depending on the final legislation.

If I am self-employed and paid a bonus in crypto, do I need to issue an invoice?

In most cases, yes. While arguments may exist in specific structures for not issuing an invoice, proper invoicing with the correct VAT wording significantly reduces the risk of disputes in the event of a tax audit.