Belgium Adopts List of Countries not Eligible for the Participation Exemption

On 27 November 2015, the Belgian government adopted a Royal Decree for a revised list of countries that are not eligible for the application of the participation exemption. Under Belgium's participation exemption regime, 95% of qualifying dividends (100% for capital gains) are exempt. However, the exemption regime is generally not available for distributions from countries in which the profits of companies benefit from a special tax regime where the nominal corporate income tax rate or the ac…