New ‘60-day rule’ for pension funds: the practice note was published
Quick recap Since 1 January 2017, a specific anti-abuse prevents to benefit from a WHT exemption when the Belgian tax administration proves that the dividends concerned are linked to a (set of) legal act(s) that are not genuine and aimed, even incidentally, at benefiting from the WHT exemption concerned. Since 22nd January 2019, the fact
Former prohibition of exemption of withholding tax on dividends distributed by Belgian Regulated Real Estate Companies annulled by Constitutional Court
On 11 May 2016, the Belgian Constitutional Court annulled the former prohibition of exemption of withholding tax on dividends distributed by Belgian Regulated Real Estate Companies (RRECs) on the ground that it was discriminatory compared to dividends paid by Belgian Real Estate Investment Funds (REIFs). The Act of 12 May 2014, applicable as from 16