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Belgium to Repeal the Notional Interest Deduction, Temporarily Reduce the Corporate Tax Basket Deduction, and Modify the FTC for Royalties — Orbitax Tax News & Alerts

A release from the Belgian Council of Ministers was issued on 18 November 2022, announcing the approval of a draft law containing several measures in relation to the budget, health care, social affairs, finance, and other matters. This includes several measures previously agreed to for the budget for 2023 and 2024. Some of the key measures noted in the release include:

  • A reduction of social security contributions in Q1 and Q2 2023 and the postponement of social security contributions in Q3 and Q4 2023 for employers;
  • The reform of the copyright regime;
  • The repeal of the notional interest deduction;
  • A limitation of the deduction of the annual tax on credit institutions, undertakings for collective investment, and insurance companies;
  • A temporary reduction from 70% to 40% of the "corporate tax basket" of deductions exceeding EUR 1 million, which includes losses carried forward, the notional interest deduction, carried forward dividends received deduction, etc.;
  • The modification of the foreign tax credit calculation on royalties;
  • The formalization (in law) and extension of the temporarily reduced excise duties on electricity and gas for businesses and the self-employed; and
  • An increase in excise duties on tobacco.

The draft law must now be submitted in parliament for approval.