A new circular (official tax directive) 2025/C/38 has just been published, establishing the maximum allowances for recharging, applicable in the third quarter of 2025. This circular also confirms that the flexibility of the tax administration, introduced by circular 2024/C/77, is now definitive.
What does the new circular 2025/C/38 provide?
Until now: a tolerance regime
The circular 2024/C/77 of 5 December 2024 allowed you, as an employer, to reimburse recharging costs based on a fixed rate per kilowatt-hour (kWh).
Although reimbursement based on actual electricity costs remains the standard, this circular confirmed the tolerance of the tax administration.
However, it specified that this administrative tolerance was only temporary and would end on 31 December 2025. An extension of the measure was not ruled out.
According to the tax administration, technological solutions are being developed that will soon allow for precise measurement of the electricity consumed by a worker, and consequently the amount of actual costs to be reimbursed.
From now on: a permanent measure
A new circular 2025/C/38 now extends this measure indefinitely, giving it a permanent character.
As a result, you are no longer required to calculate the actual cost of recharging for each worker, as long as no deadline is set.
Nevertheless, employers who wish to reimburse the actual electricity costs can still do so.
New higher amounts for recharging
The circular 2025/C/38 further specifies the new allowances for recharging that will be applicable in the third quarter of 2025. The following amounts apply:
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In the Flemish Region: 34.56 euro cents /kWh
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In the Brussels-Capital Region: 37.87 euro cents /kWh
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In the Walloon Region: 38.43 euro cents /kWh
These rates are the maximum amounts that you can apply from 1 July 2025 to 30 September 2025 inclusive. They will be adjusted each quarter.
As an employer, you are free to grant a lower amount. However, it is advisable to check what has been defined in your sector.
You also have the option to pay a rate without considering the worker's residence.
Why was this tolerance regime established?
In principle, the tax authorities require that the reimbursement of electricity for the company car be based on the actual costs of the worker. However, the current technology does not always allow for easy measurement of the actual electricity consumption of workers.
To avoid discouraging the greening of the vehicle fleet due to administrative burdens, the tax authorities decided at the end of 2024 that they would allow the use of a specific rate from CREG in 2025.
With circular 2025/C/38, this flat-rate reimbursement will also be possible after 2025, with no deadline for the measure being set anymore.
However, some rules must still be respected.
What does Securex do for you?
Our advice? Establish a car policy today and attach it as an annex to the employment contract of your workers who have a company car. The car policy must specify how electricity costs are reimbursed: based on actual expenses or according to the specific CREG tariff.
Our Legal Advisors are also available to assist you in developing (or reviewing) a policy tailored to your company and compliant with the specifics of your sector. Contact them by email at: myHR@securex.be.
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