Can I combine the liquidation reserve with VVPR-bis?

They are separate regimes and a distribution plan often uses both across different tranches of profit. Which is cheaper depends on your company’s age, share history and how long you can wait.

What if I need the money before the waiting period ends?

Distributing a liquidation reserve early triggers a higher additional withholding, reducing the benefit. The reserve rewards patience, so only book what you can afford to leave in place.

Did the liquidation reserve get more expensive in 2026?

Yes, for new reserves. Reserves booked from assessment year 2026 onward pay a 9.8% additional withholding after the 3-year wait (up from 5%), for an overall burden of roughly 18–20%. Reserves booked before 2026 keep the previous transitional rates — 6.5% (held 3–5 years) or 5% (held over 5 years) — so do not assume last year’s numbers still apply to a reserve you book today.

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Dividends & reserves5 min read

The liquidation reserve in 2026: new reserves now cost more to release

Published 3 February 2026Updated 19 July 2026

The liquidation reserve remains one of the most effective ways for a profitable one-person company to lower the tax on money it eventually pays out — but the exit cost changed for reserves booked from 2026 onward, and older reserves keep the previous, cheaper transitional rates.

How it works

At year-end, a small company can allocate part of its after-tax profit to a special “liquidation reserve” and pay a 10% anticipatory levy on it immediately. That money is then reserved. When it is later distributed as a dividend, an additional withholding applies — still well below the standard 30%, though the exact rate depends on when the reserve was booked.

The numbers

Pay the 10% now. For reserves booked from assessment year 2026 onward, distributing after the 3-year waiting period triggers a 9.8% additional withholding (the old 5% rate was abolished) — an overall burden of roughly 18–20% of the original profit, still well under the 30% standard. Reserves booked before 2026 keep the previous transitional rates: 6.5% if distributed after 3–5 years, or 5% if held more than 5 years. Distributed on liquidation of the company itself, the additional withholding can still fall to zero.

10% anticipatory levy when the reserve is booked
New reserves (AY2026+): 9.8% additional withholding after the 3-year wait — the old 5% rate is gone
Reserves booked before 2026 keep transitional rates: 6.5% (held 3–5 years) or 5% (held over 5 years)
Effective total for new reserves is roughly 18–20% — still well below the 30% standard dividend rate
Potentially nil additional withholding if released on liquidation of the company

The waiting period reform

A 2026 programme-law change raised the exit rate on newly-booked reserves: the additional withholding after the 3-year wait rose from 5% to 9.8% for reserves booked from assessment year 2026. Reserves booked before that keep the older, cheaper transitional rates (6.5% or 5%, depending on how long they are held). The direction is clear: reserves still reward holding, but they got noticeably more expensive going forward, and the exact rate depends on which year the reserve was constituted. Because vintages matter, tracking each year’s reserve separately is essential.

Frequently asked

Can I combine the liquidation reserve with VVPR-bis?: They are separate regimes and a distribution plan often uses both across different tranches of profit. Which is cheaper depends on your company’s age, share history and how long you can wait.
What if I need the money before the waiting period ends?: Distributing a liquidation reserve early triggers a higher additional withholding, reducing the benefit. The reserve rewards patience, so only book what you can afford to leave in place.
Did the liquidation reserve get more expensive in 2026?: Yes, for new reserves. Reserves booked from assessment year 2026 onward pay a 9.8% additional withholding after the 3-year wait (up from 5%), for an overall burden of roughly 18–20%. Reserves booked before 2026 keep the previous transitional rates — 6.5% (held 3–5 years) or 5% (held over 5 years) — so do not assume last year’s numbers still apply to a reserve you book today.

This article is general information for a one-person company (BV/SRL), not tax advice. Rules and figures change — confirm your situation with your accountant before acting.