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Belgium adopts entity-approach CFC rules

|Tax Alerts, Information Reporting, Legis ...|Belgium
Belgium

  • Belgium has adopted new CFC rules and switched from Model B (transactional approach) to Model A (entity approach).
  • Certain undistributed passive profits of a CFC directly owned by the Belgian controlling company will be taxed, unless a safe harbor applies.
  • New rules include different mechanisms to avoid double taxation, including a carryforward non-refundable foreign tax credit .
  • Broad reporting obligations apply.
 

Belgium's federal government has adopted new rules governing the taxation of the…

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