Guide for Belgian and Dutch Citizens Moving to Paraguay — 2025

Belgium and the Netherlands: why they are special cases

Among the European countries from which people most frequently move to Paraguay, Belgium and the Netherlands deserve special attention for distinct but complementary reasons.

Belgium has one of the highest tax burdens in the world (marginal income tax rate of up to 50%, plus social contributions) and a tax administration (SPF Finances / FOD Financiën) known for its aggressiveness in pursuing domicile transfers it considers artificial. The Belgian concept of tax residence combines two criteria — domicile fiscal and siège de la fortune — that are broader than those of many other countries.

The Netherlands has its own particularities: Box 3 (a tax on imputed financial wealth, levied even if the assets produce no real income) is a burden that many Dutch citizens seek to eliminate by relocating, but the Belastingdienst applies strict criteria and the exit tax on substantial holdings can generate significant obligations at the time of departure.

Belgium: what SPF Finances considers a "tax resident"

The Belgian Income Tax Code (CIR92) establishes that Belgian tax residents are individuals who have their domicile or the siège de leur fortune (seat of their wealth / centre of their economic interests) in Belgium.

The Belgian domicile is not simply the civil domicile (the address in the commune register): it is the place where the person has their habitual home, where they normally live with their family, where they have roots. The siège de la fortune is where the taxpayer habitually manages their financial interests: the centre from which they make their investment and economic management decisions.

This has a crucial implication: deregistering from the Belgian commune is not sufficient to be considered a non-resident for tax purposes. The SPF can argue that, even though you are registered in Paraguay, your real domicile or centre of economic interests remains Belgium if you maintain significant ties there.

What evidence does Belgium require to recognise the exit

For the SPF Finances to accept that you have genuinely transferred your fiscal domicile to Paraguay, the evidence you must be able to present includes:

• Deregistration from the registre de population (population register) of your Belgian commune
• Closure or significant reduction of bank accounts with Belgian banks (or switch to non-operational accounts)
• Sale or rental of Belgian properties: Keeping a property in Belgium as a "second residence" is not problematic per se, but keeping it as your effective primary residence is
• Deregistration from Belgian social security (INSS / RIZIV): If you continue contributing to the Belgian health and pension system as if it were your primary system, this indicates Belgium is your real residence
• Evidence of presence in Paraguay: Paraguayan bank statements, rent or mortgage receipts in Paraguay, medical records, service contracts, passport entry/exit stamps
• Economic activity centre transferred: If your main business or professional activity is carried out from Paraguay (meetings, contracts, clients), document that reality

Exit tax on Belgian assets

Belgium applies a taxe de sortie (exit tax) on certain assets when the taxpayer transfers their fiscal residence outside Belgium. In particular, it may apply to unrealised capital gains on significant company holdings, company pension plans with vested rights, and certain corporate reserves.

The exact scope of the Belgian exit tax depends on the individual's asset situation and has been subject to legal evolution. It is essential that a Belgian tax specialist experienced in emigration analyses your specific situation before proceeding.

Apostille of Belgian documents for Paraguay

Belgian documents needed for Paraguayan residency (criminal records, birth certificate) are apostilled by the SPF Affaires étrangères / FOD Buitenlandse Zaken in Brussels. The process is relatively fast: typically 2–4 weeks. Criminal records (extrait de casier judiciaire central) are requested from the SPF Justice.

Documents in Flemish or French must be translated by a licensed public translator in Paraguay. Complete timelines (document + apostille + translation) are usually 4–6 weeks in total.

The Netherlands: the Box 3 incentive and its conditions

The Dutch tax system divides income into three "boxes": Box 1 (employment and primary residence), Box 2 (substantial holdings) and Box 3 (savings and investments). Box 3 is the greatest incentive to leave: it taxes financial wealth (accounts, shares, funds, investment properties) at an imputed rate on a fictitious return, regardless of whether the assets actually generate that return.

For a Dutch citizen with significant financial wealth (from around EUR 50,000), Box 3 can amount to thousands of euros per year in tax on assets that may not be generating that imputed return. By transferring residence to Paraguay (territorial system with no tax on foreign wealth), this levy disappears.

But the Belastingdienst does not make it easy.

Dutch fiscal residency criteria

The Netherlands determines fiscal residence through an analysis of all facts and circumstances: there is no single 183-day rule. The factors the Belastingdienst considers include:

• Where the taxpayer's primary residence is available
• Where the nuclear family resides (spouse, minor children)
• Where the main economic activity is carried out
• Where the main bank accounts and managed investments are located
• Where the taxpayer is registered (GBA / BRP: the municipal population register)
• The number of days spent in each country

The weight of the first factors (family, housing, economic activity) tends to be greater than the mere day count. A Dutch citizen who spends 200 days in Paraguay but keeps their family in Rotterdam and manages their investments from there may still be considered a Dutch tax resident.

Dutch exit tax on substantial holdings

The Netherlands applies an exit tax on unrealised capital gains in substantial holdings (aanmerkelijk belang: holdings of 5% or more in a company's capital). Upon transferring residence, a fictitious taxable event is generated: it is as if you sold those holdings at market value at the time of departure.

The Box 2 tax rate (applicable to these gains) is 24.5% on the first EUR 67,000 of gain and 33% on the excess (2024 rates, subject to revision). This exit tax can be very significant for entrepreneurs or investors with valuable holdings.

Payment can be deferred in some cases if the relocation is to an EU or EEA country with a specific agreement, but Paraguay does not fall into that category. Managing this exit tax is one of the most critical points for Dutch citizens considering the move to Paraguay.

Apostille of Dutch documents for Paraguay

Dutch documents (Verklaring Omtrent het Gedrag / VOG for criminal records, akte van geboorte for birth certificates) are apostilled by the Ministerie van Buitenlandse Zaken in The Hague. The process can be done by post. Typical timelines are 2–3 weeks for the apostille once you have the original document.

Documents in Dutch require official translation in Paraguay. The Dutch community in Paraguay is small but present, mainly in the agricultural sector in the interior of the country (Mennonite colonies with historical Dutch ties), although urban expatriates do not speak of a significant urban Dutch community in Asuncion.

The residency process in Paraguay: the same for both

Once the fiscal exit strategy from Belgium or the Netherlands is resolved, the process of obtaining residency in Paraguay is identical for both nationalities. Paraguay does not have a specific programme for Belgians or Dutch citizens: the same residency pathways available to any European citizen apply.

The most common pathways are residency through income or retirement (demonstrating regular foreign-source income), residency through investment in Paraguay (documented investment in the country), or residency through family ties with a Paraguayan citizen or previous resident.

The complete process — from the application to Migraciones to ID card in hand — typically takes between 3 and 8 months for temporary residency, with a subsequent application for permanent residency after 2–3 years.

Exit checklist: what you must do before leaving

The absence of a DTA: same as for all Europeans

Neither Belgium nor the Netherlands has a DTA (Double Taxation Agreement) with Paraguay. This means there is no automatic bilateral tie-breaker mechanism if both administrations claim the taxpayer's fiscal residence. As we explain in detail in our guide on DTAs with Paraguay, the solution to this absence is the correct execution of the fiscal exit from the country of origin, not finding a DTA that does not exist.

Conclusion: manageable complexity with the right approach

The fiscal exit from Belgium or the Netherlands to Paraguay is more complex than for citizens of other European countries. The administrations are rigorous, the residency criteria are broad, and there may be significant exit tax obligations. But none of these complexities makes it unviable.

The key lies in three principles: advance planning (minimum 12 months before the move), specialised advice on both ends (tax specialist in the country of origin + advisor in Paraguay), and meticulous documentation of the real severance of ties with the country of origin and the establishment of effective life in Paraguay.