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E-tax Flash - Reporting of payments to tax havens

Reporting of payments to tax havens

The Royal Decree published in the BOG of 11 March 2016 updated the list of tax havens.


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The Royal Decree published in the BOG of 11 March 2016 updated the list of tax havens for which payments have to be specially reported.

This list contains countries:

  • without corporate tax 
  • or with a nominal corporate tax rate that is less than 10%

According to the verifications made by the tax authorities based on those criteria, the new list includes the following countries:

Abu Dhabi, Ajman, Anguilla, Bahamas, Bahrain, Bermuda, British Virgin Islands, Cayman Islands, Dubai, Fujairah, Guernsey, Jersey, Isle of Man, Marshall Islands, Micronesia, Monaco, Montenegro, Nauru, Uzbekistan, Palau, Pitcairn Islands, Ras al Khaimah, St. Barthelemy, Sharjah, Somalia, Turkmenistan, Turks and Caicos Islands, Umm al Quwain, Wallis and Futuna *

The Royal Decree is applicable to payments made as from 1 January 2016.

As a transitional regime, the old list remains applicable to payments made during an accounting period closing before 1 April 2016.

As a reminder, according to article 307, § 1 5th alinea of the Belgian income tax code (BITC), corporate income tax payers have to report all payments made to tax havens if in total they equal or exceed 100.000 EUR/ financial year. Are considered to be tax havens: countries that do not comply with the OECD Global Forum standard on the exchange of information or that are listed by the Belgian authorities as a country without corporate income tax or where the nominal corporate tax rate is less than 10 %. The actual royal decree is the first update of the Belgian list since its introduction in 2010. Payments that are not properly reported will be non-deductible (art. 198 §1 9° BITC).

*countries in bold are new on the list


KPMG Tax Advisers  

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B-1130 Brussels 

Tel.: +32 2 708 38 24

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