Belgium - Fairly Odd: Belgium's New Fairness Tax
- B. Michel; P. Van Den Berghe
- European Taxation, 2014 (Volume 54), No 6
- 13 May 2014
As of 2013, Belgium has been levying a new tax called the "fairness tax". The tax consists in a separate corporate tax assessment of 5.15% levied on profit distributions by Belgian companies or branches that do not realize taxable profits because of the offsetting of previous losses or the notional interest deduction. This article discusses the technical aspects of the tax, the policy design behind the provisions and, finally, its compatibility with EU law and with Belgium's tax treaties.