Belgium has affirmed that 25% withholding tax imposed on dividends if those dividends are received by Belgian investment companies would no longer be creditable and refundable. This would implement a decision of the European Court of Justice and would provide for a level playing field between resident and non-resident investment companies.
Both the resident and non-resident funds would be subject to withholding tax without a credit (or refund) for the amount of tax withheld. And foreign investment companies which are subject to Belgian withholding tax would no longer be discriminated against, as per the ECJ Ruling.
The new tax arrangements for Belgian investment companies may be applied from 2013. However, as the legislation still needs to be approved by parliament these tax measures could be subject to change during the legislative process.
