In the framework of the expected corporate income tax reform (further to the agreement reached at government level last summer), the Belgian government intends increasing the participation exemption (dividend received deduction), which under current legislation is limited to 95% of the dividend income received, to a 100%-deduction. As a result, dividends received by a Belgian (parent) company from its subsidiaries would qualify for a full exemption. This measure should increase Belgium’s attractiveness as a holding jurisdiction.
The full participation exemption would apply as of tax year 2019 (i.e., in principle, financial year 2018).
Of course we will follow-up this important development, and keep you informed.