Employer specific variable costs

Employer specific variable costs

What is the new obligation?

From the year 2022 onwards, all variable remunerations that the employer or company grants to its employees or managers as reimbursement of the employer’s own actual expenses must also be justified by stating the amount on the tax form.

Variable remuneration refers to reimbursements based on supporting documents.

Broader reporting requirements for variable expense reimbursements…

The law of 27 June 2021 amends the existing regulations.

Variable allowances granted to staff members from 1 January 2022 onwards as reimbursement of the employer’s own expenses must now be justified in the individual forms (281.10/281.20). The actual value of the variable allowances must therefore be included in these sheets.

In this way, the legislator wishes to combat the duplication of the reimbursement of the employer’s own expenses and to avoid the unjustified deduction of professional expenses by the beneficiary.

… not without administrative formalities

The wider reporting obligation creates a lot of administrative formalities. A concrete procedure will have to be put in place to ensure that the information on expenses reimbursed by the financial department is also communicated to the payroll manager.


While the new reporting requirement means a lot of red tape, employers who do not comply with the regulation still retain the right to deduct benefits paid to their staff. Any non-compliance will not result in a secret commission assessment.

Watch out for controls!

The explanatory memorandum of the law of 27 June 2021 already mentioned that the wider record obligation would contribute to the control of possible duplication of flat-rate allowances and reimbursements based on supporting documents.

To avoid discussions with the tax authorities, we advise you to apply for a tax ruling from the Advance Rulings Service if you are reimbursing expenses in a lump sum.


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