Belgium's holding company regime - past, present and future

This article describes the origins of Belgium's holding company regime and reviews its current features to determine how the rules could, or should, evolve to bring the regime into compliance with EU law and how the rules should be enhanced to attract more investment to Belgium. After summarizing the historical development of Belgium's holding company regime, the article examines the requirements of the current regime, considers the regime in light of EU law and tax treaties, and gives three main proposals for improving it.