‘20 Percent for 2020’: A Scenario for Belgium’s Corporate Tax Reform

Caterpillar, a U.S. multinational corporation, recently announced its intention to close its plant in Gosselies, Belgium, where it manufactures heavy machinery. While the news was not unexpected, it still came as a shock to the 2,200 employees who will lose their jobs. In 2013, 1,400 jobs were lost in a restructuring. Walloon Minister-President Paul Magnette said he was shocked and …

Belgium Abolishes Patent Box, Introduces Innovation Box

Apart from the correction of a piece of legislation introduced at the end of last year (following Tate & Lyle), Belgium’s recently published Act of August 3, 2016, deals mainly with the abolition of the patent box, which provides an 80 percent deduction of patent income related to the development or enhancement of patents. To read more, click here.

A new Tax Regime for the Diamond Sector

Belgium’s controversial diamond regime, which the European Commission announced was in line with state aid rules, will enter into force for tax year 2017. Belgium’s July 24, 2015, program law introduced a special tax regime for diamond traders, in which they will pay tax on 0.55 percent of their turnover rather than on the actual profits from their diamond trading …

New Tax Measures under the Programme Law

The Programme Law of July 1 introduced a number of fiscal measures, including transfer pricing documentation in line with action 13 of the OECD’s base erosion and profit-shifting project and measures to combat tax fraud. To read more, click here.

Tax Regime for the Sharing Economy,

The Programme Law of July 1, 2016, sets up a framework for taxing income received from the sharing economy, consisting of an advantageous (but limited) tax regime for personal service providers who run through a digital platform and tax withholding at source by the digital platform. The sharing, or peer-to-peer, economy is booming as digital platforms and apps (such as …

Belgium introduces Transfer Pricing Documentation

Apart from the new tax regime for the sharing economy, the Programme law of 1 July 2016 (Belgian State Gazette 4 July 2016) introduced a number of other fiscal measures, including provisions that introduce transfer pricing documentation in line with Action 13 of the OECD’s BEPS project and other budgetary measures, including measures to combat tax fraud. The Law implements …

New Penalties for Failure to Report Legal Arrangements

In 2015, Belgium introduced a transparency or “look-through” tax for legal arrangements such as trusts and trust-like arrangements and for other legal arrangements that have legal personality. The founder or the sponsor of such legal arrangement is taxed on the income of the legal arrangement as if it was his personal income, unless a beneficiary has received the income. Moreover, when …

Belgium Extends Reporting of Payments to Tax Havens

Since 2010 Belgian companies and permanent establishments of foreign companies must report in their annual tax return all (direct and indirect) payments they have made to tax havens (art. 307 ITC 1992) for a total of EUR 100,000 or more. If they are not reported, these payments are not tax deductible. When reported, such payments are only tax deductible if …

Belgium updates list of tax havens

In two Royal Decrees dated 1 March 2016 (published in the Belgian State Gazettes of 10 and 11 March 2016), the Minister of Finance has updated the list of countries which are deemed to have an advantageous tax regime. The first list relates to the participation exemption, the basis for the Belgian holding company regime. One of the conditions for the participation …

Switzerland, as a direct democracy, organises about five referendums every year.  On Sunday, Swiss voters have rejected proposals to restrict immigration and to abolish the favourable tax regime for wealthy foreigners living in Switzerland. The major issue in the referendum of 30 November was the initiative “Save Our Swiss Gold”, that would have obliged the government to increase its gold …