General tax law

We take an international view, without of course losing sight of the Belgian tax system. To assist you as well as possible, we continue to delve into various aspects of tax law. We are happy to help you in the following tax disciplines:

• Income tax: advice on all aspects of personal taxation, corporate taxation, tax on legal persons, taxation of non-residents and advance levies;
• European and international tax law: advice on the application of tax treaties, impact of European regulations and directives, protection of basic rights;
• Inheritance and registration tax
• Various duties and taxes

Our many years of experience in the field of tax law includes advising on the following topics, among others:

• copyright;
• equity incentives (share option plans, etc.);
• status of foreign executives, etc.;
• Cayman tax;
• optimisation of investment tax system;
• tax risk assessment;
• transfer of companies and exemption capital gains on shares;
• intellectual property;
• cryptocurrency;
• tax incentives for start-ups or innovation;
• holding and management structure, whether or not in the context of asset planning;
• joint ventures and reorganisations;
• tax due diligence;
• foundation and tax guidance good causes;
• tax privacy;
• obligatory tax declaration;

International tax law

Introduction

As the name of our firm suggests, our focus is international. We assist clients with dossiers that involve a foreign link in a wide variety of ways. We analyse tax treaties as well the internal Belgian rules to prevent double taxation. We concentrate in particular on migration and emigration, guidance on cross-border investments and international labour taxation, including pensions.

Relocation

Whether you are emigrating or immigrating, there are all sorts of aspects to be taken into account when relocating. One country’s laws do not necessarily apply in another country. If you want to move abroad but you have questions about the tax implications of the move (for your pension, for example) and the country you have chosen, we examine all the possibilities and any alternatives. If your company is relocating too, or is being sold, we ensure that this is done in accordance with the appropriate tax rules. And of course, we make sure the procedures are handled properly and provide information on the measures to be taken, such as structuring your assets, your social security, etc. Similarly, if you are planning to relocate to Belgium from abroad and will still be receiving income from your country of origin, for example, we will investigate the tax implications in detail.

Cross-border investments

We assist you with tax matters in word and deed if you are looking to invest in real estate abroad or in private equity. Should you do so through your company, or is it preferable not to do so? Or would it be better to set up a company abroad? These choices are vitally important. Making the wrong decision at the outset can cost dearly in terms of tax, especially if your investment yields returns and you want to channel them back into Belgium. Conversely, we can ensure that as a foreign investor, you can invest properly in Belgian assets.

Doing business internationally

From start-ups to experienced entrepreneurs, more and more people are doing business internationally. Many of our clients are internationally structured companies. Needless to say, our firm has what it takes to assist these companies with their tax. Sometimes a foreign project does not need a heavy structure and opening a branch is sufficient. In other cases, it may be better to set up a new company abroad, if only to safeguard against the business risk.

International labour taxation

Doing business abroad does not only offer tax opportunities for the director’s remuneration received by entrepreneurs. CEOs, CFOs, executives, etc. can also benefit thanks to sound tax advice which we are happy to provide for them and the company in which they work. This applies not only for taxpayers working abroad, but also for expats who come to live and work in Belgium. For the latter, Belgium can grant a particularly attractive tax status on request. Top athletes and artists especially work internationally, and usually not just in one or two countries, but in many different locations. Their tax situation is correspondingly complex. We have now built up particular expertise in this area and would be pleased to advise you. Finally, good tax advice is obviously essential when retirement approaches. Is your foreign pension taxable in the country where the pension fund or insurance company is established or are you liable for Belgian taxes? And if Belgium can levy tax, does this apply at all times? Or can Belgium still tax your Belgian supplementary pension if you no longer live in Belgium?

Relations with the tax authorities

Rulings

We are happy to adopt a position: our analysis does not depend on the way the tax authorities address an issue. However, it may be advisable to sort out the tax consequences of a transaction with the tax authorities beforehand. Because there are no precedents, for instance. Or because above all you want peace of mind about your tax affairs. This can be done by means of an informal tax agreement or a more formal ruling procedure. Moreover, a ruling procedure like this can be started up anonymously.

Tax disputes:

We defend you or your company before and during a tax inspection and/or a complaint procedure, keeping an eye on the limits of the tax authorities’ powers of inspection. In addition, we can assist you with any mediation with the tax authorities. After all, sometimes a good agreement is better than a bad ruling. However, if a dispute on tax proves unavoidable, we do not hesitate to bring the matter before a court. We have appeared before the highest Belgian and European bodies and we always conduct negotiations and proceedings in your best interest.

Tax regularisation:

Transparency is high on the agenda of governments worldwide. Belgian measures have enlarged the obligation to declare your foreign assets and asset structures. International data exchange gives the tax authorities a broader view than ever of your movable and immovable assets. We have extensive expertise in dealing with these dossiers. If the tax laws have been infringed, we can of course provide guidance on the administrative correction or tax regularisation of your assets.