On 6 May 2019, Belgium published in the Official Gazette the Law of 28 April 2019 on various tax provisions. One of the main measures of the Law is the amendment of Article 264 of the Income Tax Code, which provides for an exemption from withholding tax on dividends in certain cases.
The amendment is the addition of an exemption for dividends (shares) allocated or attributed to Belgian residents by a foreign distributing company in relation to a spin-off, where the foreign company contribu…