Belgium: Guidance on new controlled foreign company rules

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

Share
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

Thank you!

Thank you for contacting KPMG. We will respond to you as soon as possible.

Contact KPMG

Use this form to submit general inquiries to KPMG. We will respond to you as soon as possible.

By submitting, you agree that KPMG LLP may process any personal information you provide pursuant to KPMG LLP's . Privacy Statement

An error occurred. Please contact customer support.

Job seekers

Visit our careers section or search our jobs database.

Submit RFP

Use the RFP submission form to detail the services KPMG can help assist you with.

Office locations

International hotline

You can confidentially report concerns to the KPMG International hotline

Press contacts

Do you need to speak with our Press Office? Here's how to get in touch.

Headline