4. Spain France Italy Germany Denmark United Kingdom Ireland The Netherlands Brussels London Belgium Switzerland Dublin Barcelona Rome Paris Frankfurt Milan Bern Luxembourg Amsterdam The economic power- base of Europe
23. Reason #7 Top Business Infrastructure Ranking of Major European Distribution Locations Cushman & Wakefield, 2008 Italy 10 Slovenia 9 Germany 8 Austria 7 France 6 Poland 5 Czech Republic 4 Hungary 3 Netherlands 2 Belgium 1
29. Reason #9 Highly Attractive Tax Regime ( n.b. ) - Effective average corporate tax rate 2009 (based on asset and source of finance) - Especially in Belgium, the EATR is considerably below statutory tax rates (-9.3) Source : Report 2009, made by ZEW (Centre for European Economic Research) for the EU Commission (Project Taxud/2008/CC/099), Mannheim and Oxford, October 2009
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33. Reason #9 Highly Attractive Tax Regime EXAMPLE NID : Assets Liabilities Group Financing 10,000 Share capital 10,000 P & L account Before notional interest deduction With notional interest deduction Profit before tax 400 400 Notional interest deduction (3.8 %) / - 380 Taxable 400 20 Corporate tax (33.99 %) 135.96 6.79 Effective tax rate 33.99 % 1.70 %
34. Reason #9 Highly Attractive Tax Regime EXAMPLE 2 NID : Assets Liabilities Business Assets 10,000 Share capital 10,000 1.70 % 4 % Net result (return on equity) Effective tax rate ≤ 3.8% 0 % 5 % 8.15 % 8 % 17.84 %
Because I think that a examples will prove the advantages better than I can say it. On the balance sheet above you see that the share capital of this Belgian entity has been used for group financing. With an intra-group interest rate applied of 4% the profit before taxes is 400 and currently you will pay around 136 of corparate tax. With notional interest deduction you will deduct 3.781% of the 10,000 share capital and you will pay less 7.44 of corporate tax, which brings the effective tax rate back to 1.86%
Let’s take the same example – but for another operational company in the production field or in any other business. Depending on your return on equity you can see that the effective corporate tax rate is indeed very interesting. With a net return on equity of less than 3.781%, you pay no corporate tax. With a net return on equity of 10 % you will have an effective tax rate of about 21%. In between you can see the rates for other cases. This positions Belgium very favorably on the international tax map.