Belgium adopts entity-approach CFC rules

22 January 2024|Tax Alerts, Information Reporting, Legislation & Policy, National/Federal Taxation|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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