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Belgium: Government reaches agreement, legislation implementing corporate tax reform

Belgium: Government reaches agreement

The Belgian government has reached an agreement on legislation for implementing corporate tax reform.


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The corporate tax reform would take place in two phases: in 2018 and 2020. Under the tax reform, the rate of corporate income tax for “large companies” would be:

  • 29% as from income 2018 (assessment year 2019)
  • 25% as from income 2020 (assessment year 2021) 

The crisis contribution (currently at 3%) would also be reduced in two steps: 

  • 2% as from 2018 
  • 0% as from 2020


Other changes include the introduction of a minimum tax base for companies with a taxable profit that exceeds €1 million by limiting certain deductions (grouped in a “basket”) to 70% of the taxable profit exceeding €1 million. Among the deductions to be included in the “basket” are the following items (and in this order):

  • The notional interest deduction
  • The dividends-received deduction carryforward
  • The innovation income deduction carryforward
  • The deduction of losses carried forward and the (old) notional interest deduction carried forward

The dividends-received deduction for the assessment year, the innovation income deduction for the assessment year, and the investment deduction would not be included in the basket. 


Read an October 2017 report prepared by the KPMG member firm in Belgium

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