21 March 2018 Belgium introduces 100% participation exemption The Belgian corporate income tax reform, in addition to decreasing the corporate income tax rate to 25% by 2020 (29.58% in 2018 and 2019), also amended a number of measures to increase the attractiveness of Belgium as a holding jurisdiction. Specifically, the dividends received deduction has been increased from 95% to 100% and a full exemption also has been introduced for qualifying capital gains on shares. In addition, further to the implementation of the European Union (EU) Anti-Tax Avoidance Directive (ATAD), Belgium has opted to implement controlled foreign corporation rules that only target non-genuine operations, which is a less intrusive method than targeting all low-taxed passive income. Document ID: 2018-0614 |