To recall, if the total of contributions paid into occupational pension plans for one person exceeded EUR 30,000 in 2011, the company has to pay a special contribution of 1.5% on the excess amount. This charge is due both for employees and for self-employed company directors.
For employees, the special contribution has to be reported in the social security return of the fourth quarter of 2012. This return has to be filed by the end of January 2013 (or 14 working days later if this is handled by a payroll agency). The payment is due at the same time.
For company directors, the payment has to be made to the National Institute for the Social Security of the Self-employed by 28 February 2013 (bank account number: BE06 6790 0247 5722). Via its website, www.rsvz.be, the reference to be used for the bank transfer can easily be generated using your company number.
In our December 2012 pension alert, we described the manner in which the calculation needs to be done.
Most pension providers (insurers and pension funds) will normally contact their clients, insofar as they exceed the ceiling, to alert them of this new obligation. In some situations, however, some action is required on the part of the company.
An example of this is a situation where an employee/director is a member of two or more pension plans that are managed by different pension providers and where the ceiling is not exceeded in any of the plans individually. In that case, none of the pension providers will notify the client. It will be entirely up to the company to check whether the sum of the contributions paid into all pension plans combined for that employee/director does not exceed the ceiling. PwC is available to assist, also with the related calculations.
As the pension database is administered by a body called Sigedis (www.sigedis.be), the Belgian authorities will be able to check whether the so-called ‘Wijninckx bijdrage’ has been paid when due. That is why we wish to alert our clients to the need to proactively check whether the ceiling is exceeded, in particular if the company has pension plans in place with more than one pension provider.