background image
2.2. Tax Consequence of Contributions

There is no capital duty upon incorporation or subsequent capital contributions. Only a fixed duty of EUR 25 applies. There are no further capital contribution levies and no capital gain is realized at the level of the shareholder upon the contribution of assets to the capital of a company. A notarial deed is subject to stamp duties.

Tax on the Delivery of Securities to Bearer

Each "delivery" of security to bearer is subject to stamp duty in case this delivery relates to Belgian or foreign public financial instruments to bearer (i.e. securities to bearer the nature of which allows a quotation on the stock exchange).

A "delivery" is in this respect defined as each material delivery resulting from among other things:

  • a subscription;
  • an acquisition for consideration; or
  • a conversion of registered securities into securities to bearer.

This stamp duty amounts to 0.2%. Note however that there are several full exemptions from this tax on the delivery of securities to bearer (e.g. in case the securities are acquired without the intervention of professional intermediaries).

As far as original issues are concerned, the tax on physical deliveries was abolished. The tax remains in effect, however, for deliveries on the secondary market.