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Belgium: Guidance on new controlled foreign company rules

Two circular letters clarify certain aspects of new CFC rules introduced last year

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December 23, 2024

The tax authorities published two circular letters clarifying certain aspects of the new controlled foreign company (CFC) rules introduced last year.

The clarifications focus especially on (1) the determination of whether a foreign company is subject to the CFC rules (i.e., subject to an income tax rate that is less than half of the corporate income tax that would apply if the foreign company were a Belgian tax resident), and (2) whether a foreign company qualifies for an applicable safe harbor (e.g., safe harbor for performance of substantial economic activity).

Read a December 2024 report prepared by the KPMG member firm in Belgium

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