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BUSINESS SCENARIOS
FOR LOGISTICS
YOU WANT TO MAKE THINGS MOVE
YOU LIKE TO BE IN THE CENTER
AND YOU ARE A TEAM PLAYER
DISCOVER FLANDERS
CENTRALLY LOCATED
HIGHLY EFFICIENT MULTIMODAL
INFRASTRUCTURE
OPEN AND FRIENDLY
ENVIRONMENT
NOTIONAL INTEREST
DEDUCTION
PLENTY OF
(LOW-COST)
SPACE
HIGH QUALITY
OF LIFE
HIGHLY SKILLED
AND MOTIVATED TALENT
MULTILINGUAL
DENMARK
NORWAY
SWEDEN
CZECH REP.
POLAND
AUSTRIA
UK
IRELAND
ITALY
FRANCE
SPAIN
PORTUGAL
SWITZERLAND
FLANDERS
NETHERLANDS
BELGIUM
GERMANY
 The accessibility of Flanders is fabulous, [...],
I can make one day business trips to our customers in other
European countries. No transiting around, just perfect.”
Tej Soni, President & Founder, izmocars (India)
2
Over 60% of European purchasing power is situated
within a tight 500-kilometer radius around Flanders.
Large industrial and consumer areas such as Paris,
the Ruhr area, London and the Amsterdam-Randstad
area are within a stone’s throw.
LOOKING FOR
THE IDEAL PLACE
TO SET UP YOUR LOGISTICS
OPERATIONS IN EUROPE?
FLANDERS, THE NORTHERN REGION OF BELGIUM,
IS THE EUROPEAN GATEWAY PAR EXCELLENCE!
A bold statement but we have the prime location and
logistics strengths to back it up.
WHY IS FLANDERS IN POLE POSITION?
1 Our central location means the shortest
route to European customers.
2 Highly efficient and outstanding multimodal
infrastructure connects you fast to the
rest of Europe and the world.
3 Our open and friendly environment – economically,
politically, fiscally and socially – makes doing business
in Europe easy and attractive.
Our long history as a key player in logistics is
demonstrated by the latest three editions of the
biennial European Distribution Report by Cushman 
Wakefield, which puts us in first place as top logistics
location in Europe.
Logistics hotspots in Flanders’ multi-modal transport infrastructure
PRIMARY HOTSPOT
1.	 Gateway cluster
2.	 Canalzone Ghent
3.	 Cluster Ghent-South
4.	 Cluster Waasland Port
5.	 Sint-Niklaas
6.	 Cluster Mechelen
7.	 Corridor A12-E19
8.	 Seaport of Antwerp
9.	 Corridor ENA
10.	Cluster Limburg-West
11.	Node Diest
12.	Cluster  Middle‑Limburg
SECONDARY HOTSPOT
A.	 Node Aalter
B.	 Roeselare
C.	 Kortrijk
D.	 Node Waregem
E.	 Leie Space
F.	 Node Aalst
G.	 Node Ternat
H.	 Corridor E19
ZuidLeuven
I.	 Node Turnhout
J.	 Cluster Limburg-North
K.	 Node Tienen
L.	 Node Tongeren
M.	 Node Lanaken
3
HIGHER EFFICIENCY
Flanders is located close to all the major
European industrial and consumer markets,
making it an ideal logistics hub. With the
seaports of Antwerp, Ghent, Zeebrugge
and Ostend, Flanders boasts extensive
ocean-going gateways for the speedy
handling of all kinds of goods to and from
anywhere in the world. Close-by, Brussels
Airport, Antwerp International Airport and
Ostend-Bruges International Airport take
care of the fast and efficient shipment of
your goods by air. Our road, rail and inland
waterway networks are among the densest
in Europe and provide fast connections
with the European hinterland. From our
region, logistics companies and distribution
centers can transport goods to most major
European markets within 24/48 hours by
any mode.
EXTENDED GATEWAY®
With the unique concept of “The
Extended Gateway®
”, Flanders offers an
integrated vision on logistics. It defines
clusters of companies with comparable
logistics characteristics which, in turn,
makes it possible to bundle the flow of
goods. Finding your prime location in
the hinterland of Flanders, close to an
inland multimodal terminal, is therefore
guaranteed. The Extended Gateway®
allows
you to be sited on a location where your
total logistics costs are the lowest.
INNOVATION IN LOGISTICS
The Flanders Institute for Logistics (VIL)
is a center of expertise that supports
Flanders-based companies – with financial
aid and advice, and through networking – in
implementing innovative logistics projects
and increasing their competitiveness.
VIL works closely with players from the
logistics sector: shippers, third-party
logistics providers and the like. It focuses
primarily on multimodality, one of the
biggest assets of Flanders.
Want to know more?
Check www.vil.be/en
4
WELCOME
TO FLANDERS!
A WARM
LOWER EFFECTIVE TAX RATE
The government of Flanders has created
a high-quality business climate for the
companies that settle in our region.
Our intensive support, sound advice and
substantial measures are geared to your
business objectives and needs. In addition you
can benefit from a favorable tax environment.
DECISIVE CORPORATE TAX MEASURES:
• Tax rulings: avoid legal pitfalls with this
powerful risk management instrument.
It offers you legal certainty on the
application of tax laws. Once you have
obtained – at no charge - an advance
decision from the Rulings Office, there
will be no unpleasant tax surprises.
• Notional Interest Deduction (NID): all
companies using their own resources to
finance their activities are eligible for this
attractive tax deduction (no need of a ruling).
Subsidiaries and branches can claim tax
relief (FY2013: 3%) for their cost of capital
by deducting a notional interest charge on
their net equity, which brings the effective
corporate tax rate to below 15% and if certain
conditions are met, even lower than that.
Taxable
profit
Profit which
would have
accrued
between
unrelated
parties
Profit accrued
based on
conditions
agreed
between
the related
parties
Tax-exempt
“Excess profit”*
EUR 4 mio EUR 10 mio EUR 4 mio *
Art. 185. 2,b)BITC
“Downward” profit adjustment
Arm’s length profit
Belgian
accounting profit
Belgian
taxable profit
• If you also envisage R  D activities, the
tax charge can be further substantially
reduced by innovative tax measures,
including the Patent Income Deduction
(entitling to 80% tax deduction of
qualifying patent income), investment
deductions and partial exemptions
of withholding tax on salaries for
qualifying researchers.
• Excess Profit Ruling: the tax office
refrains from taxing the profits of a
Flanders-based entity that it could not
have realized in a stand-alone situation.
5
THE PREFERRED LOCATION
OF EXPATRIATES
Flanders also offers fiscal advantages for
Human Resources management. Thanks to
the Expatriate Taxation, foreign executives
and managers temporarily employed in
Flanders can benefit from a special tax
status. The expatriates are treated as
non-residents in Flanders for income tax
purposes and therefore achieve significant
benefits, thus mitigating the cost of
employment in Flanders.
BECAUSE THERE ARE BETTER WAYS TO
SPEND YOUR MONEY…
Brussels, the capital of Flanders, stands
out as an inexpensive city to live in for
expatriates, according to Mercer’s ‘2011
Cost of Living Survey’. Brussels was ranked
only 62nd in the list of the world’s most
expensive cities for expatriates. Only 3 EU
capitals do better: Lisbon (86), Warsaw (102)
and Budapest (113). Brussels’ high score is
mainly due to its relatively low cost of living
with an average rental price for a luxury
apartment of EUR 1,500.
IN FLANDERS, LIFE IS GOOD!
Belgium, and Flanders as a region, is
known the world over for its excellent
quality of life. The social fiber in Flanders
is strong and people are open-minded.
The region offers an exceptionally high
standard of living for expatriates and their
families with first-class healthcare, high-
quality housing at affordable prices and an
excellent education system – one of the best
worldwide – including many international
schools. Furthermore, our rich cultural
heritage and exquisite culinary tradition
make living in Flanders an unforgettable
experience.
HALLO, BONJOUR,
GUTEN TAG AND HELLO
Flanders offers highly skilled and motivated
talent. Located right on a nodal point where
Europe’s three major cultural and language
groups meet, people in Flanders, Belgium’s
northern region, are multilingual. They
fluently speak Dutch, French and German
– the 3 official languages in Belgium – and
possess an excellent knowledge of English.
Building on the competencies we
have developed as the logistic provider
for the two Volvo factories, we expanded
our service offering with new activities for
new customers. What’s more, we benefit
from the abundance of logistical and
technological skills and competencies in
Flanders as well as from the high density
flow of goods that cross the region. That’s
how we turned into a true fourth-party
logistic provider.”
Volvo Logistics
We were very happy with the federal
government’s initiative to introduce the
notional interest deduction and favorable
taxation measures for expat employees.”
Alex Janssens, Director European Accounting
 Treasury, Finance and Administration,
Mazda Motor Logistics Europe
6
HOW TO ENSURE PROPER IMPORT
CLEARANCE OF NON-EU GOODS INTO THE
EU VIA FLANDERS
Three main factors determine treatment of
imports into Flanders:
1 Commodity code: an alphanumeric code
to classify goods and services for easy
identification, taken from the Combined
Nomenclature. You can obtain a Binding
Tariff Information (BTI), issued on request
by the customs authorities. This is the
correct tariff classification for goods you
intend to import or export. The decision is
valid in all EU member states for six years.
2 Origin: products imported into the EU have
an origin, economic or fiscal. The former
determines import restrictions and
licenses; the latter whether a product is
eligible for preferential import duty rates.
3 Customs valuation: import duties and
VAT are usually calculated on the basis
of the customs value, as stated in the
invoice. Sometimes an alternative basis
may be agreed for paying the import
duties, e.g. first sale, cost-plus or resale
minus methods.
EASY ACCESS TO THE EUROPEAN UNION
Since the EU constitutes a customs union
(EUCU), there are virtually no borders
between member states. No customs are
levied on goods travelling within the EUCU
and a common external tariff on all goods
entering the union is imposed.
What’s more, thanks to the system of
‘secure trade lanes’ – in which supplier
and customer are registered as Authorized
Economic Operator (AEO) – our customs
operate faster and more efficiently.
AEOs can apply simplified administrative
procedures and are liable to limited custom
checks. They are also given priority over
non-AEOs.
GOOD TO KNOW
Bonded warehouses allow importers to
postpone payment of import duties and
import VAT until the final destination of
the goods is known. The bonded
warehouse can perform customs-
approved forms of handling to
add value, such as re-packaging,
conservation, testing and marketing.
Companies with bonded warehouses
in different EU countries can obtain
a single EU authorization. Belgium,
and Flanders as a region, promotes
this actively because all imports are
customs-cleared centrally. Tax is paid
in Belgium and goods can be moved
flexibly between bonded locations.
Goods from non-EU countries attract
customs duties at the common EU tariff
if no particular origin agreement has
been signed with the EU. Excise duties
are levied on specific goods produced or
released for consumption in Belgium.
Certain customs and excise duties are
refundable if the goods are exported after
the duty is paid.
GOOD TO KNOW
In 2012, prime logistics space in Flanders costs less
than EUR 60/m2
, according to FDI Intelligence – a
major economic driver of globalization through FDI.
The prime rent in Belgium, of which Flanders is the
northern region, is one of the lowest in Western
Europe, thanks to its low property and building costs.
WAREHOUSE RENTING PRICES
Q1 2012/PRICES IN €/M²/YEAR
Source: CushmanWakefield HealeyBaker,
European Distribution Report 2010
TOP - 10 EUROPEAN DISTRIBUTION LOCATIONS: 2006-2010
RANKING 2006 2008 2010
1 Belgium Belgium Belgium
2 France France Netherlands
3 Germany Netherlands Hungary
4 Netherlands Czech Republic Czech Republic
5 Czech Republic Poland Poland
6 Poland Germany France
7 Austria Hungary Austria
8 Hungary Italy Germany
9 Italy Austria Slovakia
10 UK UK Italy
Source: FDI Intelligence
Flanders/Antwerp 57,46
Lille 72,98
Rotterdam 74,52
Hamburg 79,84
Warsaw 83,06
London 266,54
7
LOCATION, LOCATION, LOCATION
Distribution centers differ in their level of activity.
For purposes that involve more than generic activities
– storage, transport, picking, etc. – and administrative
support, important criteria should be considered
when selecting your location:
• the centrality
• the presence of production centers or suppliers
• a dense transport network
• total minimal logistics cost
• flexible and multilingual workforce
If complex functions, whether or not technical, are
to be performed in the distribution center, having a
multilingual, knowledgeable and flexible workforce
at hand is crucial. Those types of distribution centers
have high added value and require highly skilled staff.
In Flanders, much effort is being focused on
value‑added concepts and technologies, such as mass
customization, reverse logistics and intelligent supply
chains. Moreover, Flanders is also the region where
innovative logistic partnerships offer companies a
significant competitive advantage.
SCENARIO
CHOOSE YOUR
	 Locating our logistic activity in Flanders was a clear and strategic decision.
That’s where we could be in the economic and geographic center of gravity of our market.
Our challenge is to keep inventory levels under control, despite the proliferation of
products with infrequent demand that is so typical of the spare parts aftermarket. We are
capable of dealing with this complexity thanks to the skills, managerial competencies and
the culture of continuous improvement that one finds in Flanders.”
SKF Logistics Services
Scenario 1
Market
intelligence 
representation
office
Scenario 2
Storage
of stock
of goods
Scenario 3
Value–Added
logistics 
Services
Scenario 4
European
Distribution
Center  regional
warehouses
Scenario 5
Fully fledged
European hub
• Holding
• Regional HQ
• Treasury
8
If and when you envisage starting
operations in Europe, you will no doubt be
asking yourself which steps to take first,
as well as questions on matters of market
penetration, the allocation of resources,
the most tax-friendly options, possible
barriers, and so on and so forth.
This handy logistics guide allows you to
discover at a glance how to structure your
logistics activities. To help you in this task,
we have defined five business scenarios
ranging from just a representative office
to a fully-fledged international distribution
center. You can therefore select the
scenario that best matches your needs,
company scale and type of industry.
Each scenario is proposed with its own
tax aspects, whether direct or indirect,
and legal implications. And you can of
course apply these scenarios in a dynamic
way, aligned with the evolving scope of
your presence in Belgium.
MARKET INTELLIGENCE 
REPRESENTATION OFFICE
STORAGE OF
STOCK
OF GOODS
VALUE–ADDED
LOGISTICS  SERVICES
EUROPEAN
DISTRIBUTION
CENTER  REGIONAL
WAREHOUSES
FULLY FLEDGED
EUROPEAN HUB
Scenario 1 and 2
ForeignCo
Scenario 1 and 2
ForeignCo
Legal framework
Belgium
Abroad
Non-taxable
Belgian presence
Belgian
Permanent
Establishment
Foreign Permanent
Establishments (PEs)
BelCo
SUBs PEs
Foreign Subsidiaries
(SUBs)
Scenario 3
ForeignCo
Scenario 4 and 5
ForeignCo
9
We operate in a demanding
context that does not tolerate
quality errors and we face a market
that is highly unpredictable. Luckily,
in Flanders we can rely on a flexible
workforce that shows affinity with
the products going through the
warehouse, and on a competent
management team with expertise in
designing and optimizing processes.
In addition, appropriate information
technology systems to support
our operations are crucial. In fact,
the use of integrated IT systems
has allowed us to develop into a
provider of logistic services for the
e-market.”
Katoen Natie
YOU ONLY NEED
MARKET INTELLIGENCE
AND AN OFFICE
WITH A VIEW
SCENARIO 1
1 2 3 4 5
10
Status
• no legal entity in Belgium
• you have a presence in Belgium
• no other activity besides market
research and representation activities
(no sales activities or sales support)
Tax aspects
• no Permanent Establishment (PE) - no
tax liability
• no VAT PE and no VAT registration
(unless the representation office is
liable to pay VAT on incoming intra-
Community services “consumed” by the
representation office)
• Belgian input VAT can be recovered via
the VAT credit refund procedure for
non-established and non-VAT registered
foreign entities.
Legal implications
• need to set up a representative office
11
YOU ONLY NEED
TO STOCK
YOUR GOODS
SCENARIO 2
Status
• no legal entity in Belgium
• you own stock (finished goods), stored
in Belgium with a third party logistics
provider
• no other activity in Belgium
Direct-tax aspects
• under Belgian tax law, you have a Bel-
gian establishment
• but, if your country has signed a double
tax treaty with Belgium,
a pure stock is not a taxable
Permanent Establishment (PE)
Indirect-tax aspects
• within the EU: only VAT liabilities
• outside the EU: VAT  customs liabilities
• storage of goods is never a PE for VAT
purposes
• VAT registration is needed if you put
the goods into free circulation in
the EU (non-EU businesses need to
appoint a VAT representative – global or
individual; EU businesses can apply for
direct registration)
• to avoid prefinancing of import VAT an
import VAT deferral license (a so-called
ET 14.000 license) without any cash
guarantee can be used
• but, supply of goods to Belgian, EU
or non-EU customers is in principle
subject to VAT:
- VAT exemption possible for intra-EU
supply of goods and export supplies to
non-EU
- reverse-charged or local VAT if goods
remain in Belgium
• bonded warehouse benefits
apply
• customs  excise duty implications
(import/storage formalities, valuation,
paperless declarations and electronic
communication)
• input VAT can be deducted via the
periodical VAT return as a Belgian VAT
registration occurs
1 2 3 4 5
12
Our logistic operations run close to our largest production plant in Europe.
Combined with the central position in the European market, this gives us advantages in
both inbound and outbound logistics. In the food industry the standards of quality and
product safety are very high. We store products that require sophisticated logistical
handling and customized products in small quantities, which adds to the complexity.
Thanks to the collaboration with partners in our supply chain, we can maximize focus on
our core competencies. For example, the outsourcing of our fleet of plastic pallets has
helped to improve our customer service.”
Barry Callebaut
	 The northern region of Belgium is the ideal connection between the south and the
north of Europe. Flanders also is very attractive in terms of infrastructure, logistics,
supply chain facilities and other services we can make use of. Delivery of our products, for
example, is outsourced to some excellent transportation companies in the area.”
Celso Armando, Manager - Director, JBS-Toledo (Brazil)
13
YOU ONLY NEED
SCENARIO 3
VALUE-ADDED
LOGISTICS 
SERVICES
Status
• no legal entity in Belgium
• deemed Belgian Permanent
Establishment (PE)
• you own stock, stored and managed in a
warehouse of Belgian PE
• you take care of VAL  VAS in Belgium
including after-sales service
Direct-tax aspects
• profits attributed to Belgian PE are
taxable in Belgium
• taxable profits of Belgian PE can be
determined on a cost-plus basis
• upfront ruling can be obtained on low
mark-up
• Belgian PE can claim Notional Interest
Deduction (FY2013: 3%) for equity
invested in the Belgian PE
Indirect-tax aspects
• for indirect tax aspects on stock, see
scenario 2
• if PE for VAT purposes, input VAT can be
deducted via the periodical VAT return
of PE
• no VAT on VAS/VAL services by Belgian
PE to your head office
1 2 3 4 5
	 Many internationally active foreign investors in Flanders outsource their value
added logistics services to the multiple third party logistics providers that Flanders has to
offer, such as for instance Belgacom, Casa, Cummins, Decathlon, Dole, Dupont, Henkel,
Lexmark, Mc Donalds, Nespresso, Pfizer, Pioneer, Telenet, Tropicana, etc.”
(a non-exhaustive list by Flanders Institute for Logistics)
14
15
SCENARIO 4
YOU NEED A EUROPEAN
DISTRIBUTION CENTER
IN BELGIUM 
REGIONAL WAREHOUSES
IN OTHER EU COUNTRIES
Status
• EDC (European Distribution Center) set
up as a Belgian legal entity
• EDC owns goods, stored in regional
warehouses
• EDC delivers VAS to regional warehous-
es and employs staff locally
• possibility to set up PEs (regional ware-
houses) of Belgian entity in other EU
countries
Direct-tax aspects
• Belgian entity is taxable in Belgium
• taxable profits of EDC can be deter-
mined on a cost-plus basis
• upfront ruling can be obtained on low
mark-up
• Belgian EDC can claim Notional Inter-
est Deduction (FY2013: 3%) for equity
invested in the Belgian PE
• Belgian EDC has no foreign PE if only
storage activities in foreign countries,
dependent on tax treaty. All profits are
taxable in Belgium.
• if deemed a foreign PE, arm’s length
profit allocation required. Profit of for-
eign PE exempted in Belgium.
Indirect-tax aspects
• Belgian VAT registration is needed,
full (VAT) bookkeeping obliged
• if goods are stored in regional warehouses
in other EU countries, the Belgian EDC may
need to register for VAT in those countries
• supply of goods to Belgian, EU or non-
EU customers by the Belgian EDC is in
principle subject to VAT:
- VAT exemption is possible for intra-EU
supply of goods and export supplies to
non-EU.
- Local VAT is due if goods remain in Belgium.
• VAT treatment of cross-border supplies
depends on terms of supply.
• to avoid prefinancing import VAT an
import VAT deferral license (a so-called
ET 14.000 license) can be obtained
without any cash guarantee. Align
customs value to the transaction price.
• A ruling in respect of classification,
origin and customs value is advisable.
• cross-border authorizations and
centralized customs clearance
• Belgian input VAT can be deducted via
the periodical VAT return
• VAT credits are refundable on a quarterly
basis, for “export” businesses license
for monthly refunds is available
1 2 3 4 5
16
It is crucial for us to be able to deliver quickly and efficiently the vehicles to the
customers’ specifications to over 50 countries in Europe. The Port of Zeebrugge is an ideal
base to do that.”
Etienne Plas, spokesman for Toyota Motor Europe
Read the full (his)story on Bose’s logistics in Flanders on page 20!
17
SCENARIO 5
YOU NEED A
FULLY-FLEDGED
EUROPEAN HUB
Status
• Belgian legal entity
• acting as a European holding and
­regional headquarter company
(­holding EU subsidiaries and branches)
• also treasury and operational activities
can be performed
Direct-tax treatments
• Belgium offers attractive holding regime
• taxable profit for regional headquarter
activities and group services can be de-
termined on a cost-plus basis
• excess profit ruling is possible if
profits of Belgian company result from
group synergies
• interest income on loans and other
taxable income can be (partly) offset
by Notional Interest Deduction
(FY2013: 3%) on equity invested in the
Belgian company
• 95% exemption for qualifying dividends
of subsidiaries
• 100% exemption of capital gains on
qualifying shares
• exemption of profits of foreign PEs
in Belgium
• withholding tax exemption on repatriation
of dividends to qualifying shareholders
Indirect-tax aspects
• holding and financial activities are ex-
empt of Belgian VAT without input VAT
credit, but the financial impact of non-
recoverable VAT can be limited if set up
as an active holding and an efficient “real
use” methodology for input VAT deduc-
tion is agreed with the VAT authorities
• in respect of the “logistics” activities,
see scenario 4 for the indirect
tax aspects
1 2 3 4 5
18
ForeignCo
BelCo
SUBs PEs
Dividend:
0% Belgian
Withholding
Tax (WHT)
NO WHT on
remittance
of profits
Dividend:
0% intra-
EU WHT
Capital
Loans
AFFORDABLE LOGISTICS OPPORTUNITIES ABOUND
Flanders is home to nearly 800 European Distribution Centers
(EDCs), and although the region already has a long history in
logistics, there is still ample capacity. The seaports of Antwerp,
Zeebrugge, Ghent and Ostend have no congestion. On average,
half a million m2
of logistics space are rented out yearly. This
mainly concerns storage facilities of 5,000 m2
or more.
In addition, Limburg, the easternmost of Flanders’ 5 provinces
and ideally located on the crossroads with the Netherlands and
Germany, is the best region in Europe for logistics activities. This
statement was validated by the Cushman and Wakefield 2010
European Distribution Report.
FULLY FLEDGED EUROPEAN HUB
	 Flanders is situated in the very heart of Europe’s buying
power and, in addition, we have excellent links to our customers in
the EMEA region from there. This is the best location in Europe.”
Luc Hooybergs, Nike ELC General Manager
19
NIKE’S LARGEST
EUROPEAN
DISTRIBUTION
CENTER
20
FLANDERS AND BOSE, A MATCH MADE IN HEAVEN
Specializing in high-end audio equipment for value seekers, Bose Corporation (US) has
been synonymous with quality and performance ever since its inception in 1964. Striving
for excellence in products as well as business and marketing potential, the company was
looking for opportunities to expand its reach in Europe. Setting up office in Flanders in
1993 marked the beginning of a unique success story that is still going on today.
The long-term relationship between Bose and Flanders is fairly unique. Over the past
two decades, the company has gradually grown its presence in the town of Tongeren in
Flanders from a modest distribution center to its European operational headquarters,
going through virtually every scenario described in this guide in the process.
CENTRALIZE AND CONQUER
	 Actually, the abolition of the European borders was Bose’s cue to reorganize its
logistics network and ensure further growth”, director of operations Gerjan Meerman
explains. According to a study conducted by PriceWaterhouseCoopers, centralizing our
European distribution center would boost customer satisfaction in the region and make
us more efficient.”
As a newly appointed logistics manager, Meerman’s remit was to turn theory into
practice by setting up a central distribution center in Europe. Meerman: “The first, and
most important question was: ‘Where?’ We ended up with a longlist of eleven places,
which was reduced to three after initial research and talks with the local authorities.
Interestingly, these ‘nominees’ were all located in Flanders (Belgium). It just turned
out that they offered the best conditions in terms of land price, labor, logistics
and tax incentives.”
In the end the decision was made to establish the center in the industrial area of
Tongeren. “From the get-go, we have had an excellent relationship with the town
council and the government. Apart from the necessary facilities – like fiber optic cable
– we got a lot of help from the authorities to get through the administrative process, not
to mention the favorable withholding tax and special ruling we enjoyed. In a relatively
short space of time, we were ready to go and, in 1995, the first commercial shipment was
dispatched. All stock from the Netherlands had already been moved.”
In 1995, Bose made further enhancements to its logistics process and the sales office in
Ternat (Flanders) moved to Tongeren as well. In subsequent years, e-commerce started
to take off. “In 2004, we had to further expand our capacity”, Meerman elaborates. “One
year later, all of our European operations – including our DotCom office and repair
center – were centralized there. In the end, it was just the most logical thing to do in
terms of cost-benefit and long-term growth. Our relationship with Flanders and the local
authorities has been excellent over the years, and we look forward to expanding our
business in the region even further in the future.”
SETTING UP
YOUR BUSINESS
IN FLANDERS?
PIECE OF CAKE!
It only takes 3 days to set up
a company in Flanders:
• Flanders Investment  Trade. SETTING UP IN FLANDERS.
Overview of the issues involved in establishing a business in Flanders,
from types of business entities, incentives, workforce to imports and
exports, competition law, and environmental regulations.
www.investinflanders.com/EN/publications
• Flanders Investment  Trade.
GUIDE FOR FOREIGN EMPLOYEES WORKING IN BELGIUM.
All the legal steps an expatriate has to go through before taking up
employment in Belgium.
www.investinflanders.com/EN/publications
• For more information on FLANDERS’ PORT AND AIRPORTS, please
check their websites: www.portofantwerp.be, www.portofghent,
www.‌portofoostende.be, www.portofzeebrugge.be,
www.brusselsairport.be, www.antwerpairport.be,
www.ost.aero
• For more info, details, testimonials and contact data,
please visit us at
www.investinflanders.com
WANT TO KNOW MORE ABOUT DOING BUSINESS IN FLANDERS?
DAY 1
Open a bank account and
deposit the minimum start-up
capital
DAY 2
Use e-deposit to draw up the
deed of incorporation and
articles of association
DAY 3
Your unique enterprise
number has been activated
21
To help you realize your ambitions, Flanders Investment  Trade can rely on a vast network of private partners,
universities, federal and regional agencies, federations, and clusters, who, each in their particular domain, can provide
you with their expertise and professional support.
Part of the service of Flanders Investment  Trade is to bring you in contact with those organizations that match your
plans, the scale of your project and your market approach. Ask your FIT investment officer for a list of partners who can
help you turn your ambitions into a complete success.
In particular, we would like to thank PwC for their contribution to this brochure.
PwC firms help organisations and individuals create the value they’re looking for. We’re a network of firms in
158 countries with more than 180,000 people who are committed to delivering quality in assurance, tax and advisory
services. Tell us what matters to you and find out more by visiting us at www.pwc.com.
Pascal Janssens
PartnerPwC Belgium
T +32 3 259 31 19
pascal.janssens@pwc.be
www.pwc.be
22
23
GUIDING YOU ALL THE WAY
Whether you are just starting up or looking to expand your
logistics operations, Flanders Investment  Trade supports
you all the way. That is our mission. We provide confidential
information and support. Our experienced staff is happy to help
you with your questions regarding multimodal infrastructure, site
selection, legal aspects associated with setting up your business
locally, investment subsidies, recruitment, and much more.
We can also introduce you to the right decision-makers and to
community life in Flanders.
CLOSE TO YOU
We have about 70 regional offices worldwide to assist you,
free of charge, wherever you are. Contact us today.
We will be delighted to help you.
WOULD YOU LIKE TO KNOW WHAT FLANDERS CAN DO FOR
YOUR COMPANY?
Visit us at www.investinflanders.com
Call us on +32 2 504 88 71 or email us at invest@fitagency.be.
Please find your contactperson in Brussels or abroad here:
For news hot off the press,
follow us on Twitter twitter.com/InvestFlanders.
beeld silhouet
nog te ontvangen
Gaucheretstraat 90 | BE-1030 Brussels | Belgium
T +32 2 504 88 71 | F +32 2 504 88 88
invest@fitagency.be | www.investinflanders.com
twitter.com/InvestFlanders
www.linkedin.com/groups

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Activity Guide Logistics: Business Scenarios for Logistics in Flanders

  • 1. BUSINESS SCENARIOS FOR LOGISTICS YOU WANT TO MAKE THINGS MOVE YOU LIKE TO BE IN THE CENTER AND YOU ARE A TEAM PLAYER DISCOVER FLANDERS
  • 2. CENTRALLY LOCATED HIGHLY EFFICIENT MULTIMODAL INFRASTRUCTURE OPEN AND FRIENDLY ENVIRONMENT NOTIONAL INTEREST DEDUCTION PLENTY OF (LOW-COST) SPACE HIGH QUALITY OF LIFE HIGHLY SKILLED AND MOTIVATED TALENT MULTILINGUAL DENMARK NORWAY SWEDEN CZECH REP. POLAND AUSTRIA UK IRELAND ITALY FRANCE SPAIN PORTUGAL SWITZERLAND FLANDERS NETHERLANDS BELGIUM GERMANY  The accessibility of Flanders is fabulous, [...], I can make one day business trips to our customers in other European countries. No transiting around, just perfect.” Tej Soni, President & Founder, izmocars (India) 2 Over 60% of European purchasing power is situated within a tight 500-kilometer radius around Flanders. Large industrial and consumer areas such as Paris, the Ruhr area, London and the Amsterdam-Randstad area are within a stone’s throw. LOOKING FOR THE IDEAL PLACE TO SET UP YOUR LOGISTICS OPERATIONS IN EUROPE? FLANDERS, THE NORTHERN REGION OF BELGIUM, IS THE EUROPEAN GATEWAY PAR EXCELLENCE! A bold statement but we have the prime location and logistics strengths to back it up. WHY IS FLANDERS IN POLE POSITION? 1 Our central location means the shortest route to European customers. 2 Highly efficient and outstanding multimodal infrastructure connects you fast to the rest of Europe and the world. 3 Our open and friendly environment – economically, politically, fiscally and socially – makes doing business in Europe easy and attractive. Our long history as a key player in logistics is demonstrated by the latest three editions of the biennial European Distribution Report by Cushman Wakefield, which puts us in first place as top logistics location in Europe.
  • 3. Logistics hotspots in Flanders’ multi-modal transport infrastructure PRIMARY HOTSPOT 1. Gateway cluster 2. Canalzone Ghent 3. Cluster Ghent-South 4. Cluster Waasland Port 5. Sint-Niklaas 6. Cluster Mechelen 7. Corridor A12-E19 8. Seaport of Antwerp 9. Corridor ENA 10. Cluster Limburg-West 11. Node Diest 12. Cluster  Middle‑Limburg SECONDARY HOTSPOT A. Node Aalter B. Roeselare C. Kortrijk D. Node Waregem E. Leie Space F. Node Aalst G. Node Ternat H. Corridor E19 ZuidLeuven I. Node Turnhout J. Cluster Limburg-North K. Node Tienen L. Node Tongeren M. Node Lanaken 3 HIGHER EFFICIENCY Flanders is located close to all the major European industrial and consumer markets, making it an ideal logistics hub. With the seaports of Antwerp, Ghent, Zeebrugge and Ostend, Flanders boasts extensive ocean-going gateways for the speedy handling of all kinds of goods to and from anywhere in the world. Close-by, Brussels Airport, Antwerp International Airport and Ostend-Bruges International Airport take care of the fast and efficient shipment of your goods by air. Our road, rail and inland waterway networks are among the densest in Europe and provide fast connections with the European hinterland. From our region, logistics companies and distribution centers can transport goods to most major European markets within 24/48 hours by any mode. EXTENDED GATEWAY® With the unique concept of “The Extended Gateway® ”, Flanders offers an integrated vision on logistics. It defines clusters of companies with comparable logistics characteristics which, in turn, makes it possible to bundle the flow of goods. Finding your prime location in the hinterland of Flanders, close to an inland multimodal terminal, is therefore guaranteed. The Extended Gateway® allows you to be sited on a location where your total logistics costs are the lowest. INNOVATION IN LOGISTICS The Flanders Institute for Logistics (VIL) is a center of expertise that supports Flanders-based companies – with financial aid and advice, and through networking – in implementing innovative logistics projects and increasing their competitiveness. VIL works closely with players from the logistics sector: shippers, third-party logistics providers and the like. It focuses primarily on multimodality, one of the biggest assets of Flanders. Want to know more? Check www.vil.be/en
  • 4. 4 WELCOME TO FLANDERS! A WARM LOWER EFFECTIVE TAX RATE The government of Flanders has created a high-quality business climate for the companies that settle in our region. Our intensive support, sound advice and substantial measures are geared to your business objectives and needs. In addition you can benefit from a favorable tax environment. DECISIVE CORPORATE TAX MEASURES: • Tax rulings: avoid legal pitfalls with this powerful risk management instrument. It offers you legal certainty on the application of tax laws. Once you have obtained – at no charge - an advance decision from the Rulings Office, there will be no unpleasant tax surprises. • Notional Interest Deduction (NID): all companies using their own resources to finance their activities are eligible for this attractive tax deduction (no need of a ruling). Subsidiaries and branches can claim tax relief (FY2013: 3%) for their cost of capital by deducting a notional interest charge on their net equity, which brings the effective corporate tax rate to below 15% and if certain conditions are met, even lower than that. Taxable profit Profit which would have accrued between unrelated parties Profit accrued based on conditions agreed between the related parties Tax-exempt “Excess profit”* EUR 4 mio EUR 10 mio EUR 4 mio * Art. 185. 2,b)BITC “Downward” profit adjustment Arm’s length profit Belgian accounting profit Belgian taxable profit • If you also envisage R D activities, the tax charge can be further substantially reduced by innovative tax measures, including the Patent Income Deduction (entitling to 80% tax deduction of qualifying patent income), investment deductions and partial exemptions of withholding tax on salaries for qualifying researchers. • Excess Profit Ruling: the tax office refrains from taxing the profits of a Flanders-based entity that it could not have realized in a stand-alone situation.
  • 5. 5 THE PREFERRED LOCATION OF EXPATRIATES Flanders also offers fiscal advantages for Human Resources management. Thanks to the Expatriate Taxation, foreign executives and managers temporarily employed in Flanders can benefit from a special tax status. The expatriates are treated as non-residents in Flanders for income tax purposes and therefore achieve significant benefits, thus mitigating the cost of employment in Flanders. BECAUSE THERE ARE BETTER WAYS TO SPEND YOUR MONEY… Brussels, the capital of Flanders, stands out as an inexpensive city to live in for expatriates, according to Mercer’s ‘2011 Cost of Living Survey’. Brussels was ranked only 62nd in the list of the world’s most expensive cities for expatriates. Only 3 EU capitals do better: Lisbon (86), Warsaw (102) and Budapest (113). Brussels’ high score is mainly due to its relatively low cost of living with an average rental price for a luxury apartment of EUR 1,500. IN FLANDERS, LIFE IS GOOD! Belgium, and Flanders as a region, is known the world over for its excellent quality of life. The social fiber in Flanders is strong and people are open-minded. The region offers an exceptionally high standard of living for expatriates and their families with first-class healthcare, high- quality housing at affordable prices and an excellent education system – one of the best worldwide – including many international schools. Furthermore, our rich cultural heritage and exquisite culinary tradition make living in Flanders an unforgettable experience. HALLO, BONJOUR, GUTEN TAG AND HELLO Flanders offers highly skilled and motivated talent. Located right on a nodal point where Europe’s three major cultural and language groups meet, people in Flanders, Belgium’s northern region, are multilingual. They fluently speak Dutch, French and German – the 3 official languages in Belgium – and possess an excellent knowledge of English.
  • 6. Building on the competencies we have developed as the logistic provider for the two Volvo factories, we expanded our service offering with new activities for new customers. What’s more, we benefit from the abundance of logistical and technological skills and competencies in Flanders as well as from the high density flow of goods that cross the region. That’s how we turned into a true fourth-party logistic provider.” Volvo Logistics We were very happy with the federal government’s initiative to introduce the notional interest deduction and favorable taxation measures for expat employees.” Alex Janssens, Director European Accounting Treasury, Finance and Administration, Mazda Motor Logistics Europe 6 HOW TO ENSURE PROPER IMPORT CLEARANCE OF NON-EU GOODS INTO THE EU VIA FLANDERS Three main factors determine treatment of imports into Flanders: 1 Commodity code: an alphanumeric code to classify goods and services for easy identification, taken from the Combined Nomenclature. You can obtain a Binding Tariff Information (BTI), issued on request by the customs authorities. This is the correct tariff classification for goods you intend to import or export. The decision is valid in all EU member states for six years. 2 Origin: products imported into the EU have an origin, economic or fiscal. The former determines import restrictions and licenses; the latter whether a product is eligible for preferential import duty rates. 3 Customs valuation: import duties and VAT are usually calculated on the basis of the customs value, as stated in the invoice. Sometimes an alternative basis may be agreed for paying the import duties, e.g. first sale, cost-plus or resale minus methods. EASY ACCESS TO THE EUROPEAN UNION Since the EU constitutes a customs union (EUCU), there are virtually no borders between member states. No customs are levied on goods travelling within the EUCU and a common external tariff on all goods entering the union is imposed. What’s more, thanks to the system of ‘secure trade lanes’ – in which supplier and customer are registered as Authorized Economic Operator (AEO) – our customs operate faster and more efficiently. AEOs can apply simplified administrative procedures and are liable to limited custom checks. They are also given priority over non-AEOs. GOOD TO KNOW Bonded warehouses allow importers to postpone payment of import duties and import VAT until the final destination of the goods is known. The bonded warehouse can perform customs- approved forms of handling to add value, such as re-packaging, conservation, testing and marketing. Companies with bonded warehouses in different EU countries can obtain a single EU authorization. Belgium, and Flanders as a region, promotes this actively because all imports are customs-cleared centrally. Tax is paid in Belgium and goods can be moved flexibly between bonded locations. Goods from non-EU countries attract customs duties at the common EU tariff if no particular origin agreement has been signed with the EU. Excise duties are levied on specific goods produced or released for consumption in Belgium. Certain customs and excise duties are refundable if the goods are exported after the duty is paid.
  • 7. GOOD TO KNOW In 2012, prime logistics space in Flanders costs less than EUR 60/m2 , according to FDI Intelligence – a major economic driver of globalization through FDI. The prime rent in Belgium, of which Flanders is the northern region, is one of the lowest in Western Europe, thanks to its low property and building costs. WAREHOUSE RENTING PRICES Q1 2012/PRICES IN €/M²/YEAR Source: CushmanWakefield HealeyBaker, European Distribution Report 2010 TOP - 10 EUROPEAN DISTRIBUTION LOCATIONS: 2006-2010 RANKING 2006 2008 2010 1 Belgium Belgium Belgium 2 France France Netherlands 3 Germany Netherlands Hungary 4 Netherlands Czech Republic Czech Republic 5 Czech Republic Poland Poland 6 Poland Germany France 7 Austria Hungary Austria 8 Hungary Italy Germany 9 Italy Austria Slovakia 10 UK UK Italy Source: FDI Intelligence Flanders/Antwerp 57,46 Lille 72,98 Rotterdam 74,52 Hamburg 79,84 Warsaw 83,06 London 266,54 7 LOCATION, LOCATION, LOCATION Distribution centers differ in their level of activity. For purposes that involve more than generic activities – storage, transport, picking, etc. – and administrative support, important criteria should be considered when selecting your location: • the centrality • the presence of production centers or suppliers • a dense transport network • total minimal logistics cost • flexible and multilingual workforce If complex functions, whether or not technical, are to be performed in the distribution center, having a multilingual, knowledgeable and flexible workforce at hand is crucial. Those types of distribution centers have high added value and require highly skilled staff. In Flanders, much effort is being focused on value‑added concepts and technologies, such as mass customization, reverse logistics and intelligent supply chains. Moreover, Flanders is also the region where innovative logistic partnerships offer companies a significant competitive advantage.
  • 8. SCENARIO CHOOSE YOUR Locating our logistic activity in Flanders was a clear and strategic decision. That’s where we could be in the economic and geographic center of gravity of our market. Our challenge is to keep inventory levels under control, despite the proliferation of products with infrequent demand that is so typical of the spare parts aftermarket. We are capable of dealing with this complexity thanks to the skills, managerial competencies and the culture of continuous improvement that one finds in Flanders.” SKF Logistics Services Scenario 1 Market intelligence representation office Scenario 2 Storage of stock of goods Scenario 3 Value–Added logistics Services Scenario 4 European Distribution Center regional warehouses Scenario 5 Fully fledged European hub • Holding • Regional HQ • Treasury 8 If and when you envisage starting operations in Europe, you will no doubt be asking yourself which steps to take first, as well as questions on matters of market penetration, the allocation of resources, the most tax-friendly options, possible barriers, and so on and so forth. This handy logistics guide allows you to discover at a glance how to structure your logistics activities. To help you in this task, we have defined five business scenarios ranging from just a representative office to a fully-fledged international distribution center. You can therefore select the scenario that best matches your needs, company scale and type of industry. Each scenario is proposed with its own tax aspects, whether direct or indirect, and legal implications. And you can of course apply these scenarios in a dynamic way, aligned with the evolving scope of your presence in Belgium.
  • 9. MARKET INTELLIGENCE REPRESENTATION OFFICE STORAGE OF STOCK OF GOODS VALUE–ADDED LOGISTICS SERVICES EUROPEAN DISTRIBUTION CENTER REGIONAL WAREHOUSES FULLY FLEDGED EUROPEAN HUB Scenario 1 and 2 ForeignCo Scenario 1 and 2 ForeignCo Legal framework Belgium Abroad Non-taxable Belgian presence Belgian Permanent Establishment Foreign Permanent Establishments (PEs) BelCo SUBs PEs Foreign Subsidiaries (SUBs) Scenario 3 ForeignCo Scenario 4 and 5 ForeignCo 9
  • 10. We operate in a demanding context that does not tolerate quality errors and we face a market that is highly unpredictable. Luckily, in Flanders we can rely on a flexible workforce that shows affinity with the products going through the warehouse, and on a competent management team with expertise in designing and optimizing processes. In addition, appropriate information technology systems to support our operations are crucial. In fact, the use of integrated IT systems has allowed us to develop into a provider of logistic services for the e-market.” Katoen Natie YOU ONLY NEED MARKET INTELLIGENCE AND AN OFFICE WITH A VIEW SCENARIO 1 1 2 3 4 5 10 Status • no legal entity in Belgium • you have a presence in Belgium • no other activity besides market research and representation activities (no sales activities or sales support) Tax aspects • no Permanent Establishment (PE) - no tax liability • no VAT PE and no VAT registration (unless the representation office is liable to pay VAT on incoming intra- Community services “consumed” by the representation office) • Belgian input VAT can be recovered via the VAT credit refund procedure for non-established and non-VAT registered foreign entities. Legal implications • need to set up a representative office
  • 11. 11
  • 12. YOU ONLY NEED TO STOCK YOUR GOODS SCENARIO 2 Status • no legal entity in Belgium • you own stock (finished goods), stored in Belgium with a third party logistics provider • no other activity in Belgium Direct-tax aspects • under Belgian tax law, you have a Bel- gian establishment • but, if your country has signed a double tax treaty with Belgium, a pure stock is not a taxable Permanent Establishment (PE) Indirect-tax aspects • within the EU: only VAT liabilities • outside the EU: VAT customs liabilities • storage of goods is never a PE for VAT purposes • VAT registration is needed if you put the goods into free circulation in the EU (non-EU businesses need to appoint a VAT representative – global or individual; EU businesses can apply for direct registration) • to avoid prefinancing of import VAT an import VAT deferral license (a so-called ET 14.000 license) without any cash guarantee can be used • but, supply of goods to Belgian, EU or non-EU customers is in principle subject to VAT: - VAT exemption possible for intra-EU supply of goods and export supplies to non-EU - reverse-charged or local VAT if goods remain in Belgium • bonded warehouse benefits apply • customs excise duty implications (import/storage formalities, valuation, paperless declarations and electronic communication) • input VAT can be deducted via the periodical VAT return as a Belgian VAT registration occurs 1 2 3 4 5 12
  • 13. Our logistic operations run close to our largest production plant in Europe. Combined with the central position in the European market, this gives us advantages in both inbound and outbound logistics. In the food industry the standards of quality and product safety are very high. We store products that require sophisticated logistical handling and customized products in small quantities, which adds to the complexity. Thanks to the collaboration with partners in our supply chain, we can maximize focus on our core competencies. For example, the outsourcing of our fleet of plastic pallets has helped to improve our customer service.” Barry Callebaut The northern region of Belgium is the ideal connection between the south and the north of Europe. Flanders also is very attractive in terms of infrastructure, logistics, supply chain facilities and other services we can make use of. Delivery of our products, for example, is outsourced to some excellent transportation companies in the area.” Celso Armando, Manager - Director, JBS-Toledo (Brazil) 13
  • 14. YOU ONLY NEED SCENARIO 3 VALUE-ADDED LOGISTICS SERVICES Status • no legal entity in Belgium • deemed Belgian Permanent Establishment (PE) • you own stock, stored and managed in a warehouse of Belgian PE • you take care of VAL VAS in Belgium including after-sales service Direct-tax aspects • profits attributed to Belgian PE are taxable in Belgium • taxable profits of Belgian PE can be determined on a cost-plus basis • upfront ruling can be obtained on low mark-up • Belgian PE can claim Notional Interest Deduction (FY2013: 3%) for equity invested in the Belgian PE Indirect-tax aspects • for indirect tax aspects on stock, see scenario 2 • if PE for VAT purposes, input VAT can be deducted via the periodical VAT return of PE • no VAT on VAS/VAL services by Belgian PE to your head office 1 2 3 4 5 Many internationally active foreign investors in Flanders outsource their value added logistics services to the multiple third party logistics providers that Flanders has to offer, such as for instance Belgacom, Casa, Cummins, Decathlon, Dole, Dupont, Henkel, Lexmark, Mc Donalds, Nespresso, Pfizer, Pioneer, Telenet, Tropicana, etc.” (a non-exhaustive list by Flanders Institute for Logistics) 14
  • 15. 15
  • 16. SCENARIO 4 YOU NEED A EUROPEAN DISTRIBUTION CENTER IN BELGIUM REGIONAL WAREHOUSES IN OTHER EU COUNTRIES Status • EDC (European Distribution Center) set up as a Belgian legal entity • EDC owns goods, stored in regional warehouses • EDC delivers VAS to regional warehous- es and employs staff locally • possibility to set up PEs (regional ware- houses) of Belgian entity in other EU countries Direct-tax aspects • Belgian entity is taxable in Belgium • taxable profits of EDC can be deter- mined on a cost-plus basis • upfront ruling can be obtained on low mark-up • Belgian EDC can claim Notional Inter- est Deduction (FY2013: 3%) for equity invested in the Belgian PE • Belgian EDC has no foreign PE if only storage activities in foreign countries, dependent on tax treaty. All profits are taxable in Belgium. • if deemed a foreign PE, arm’s length profit allocation required. Profit of for- eign PE exempted in Belgium. Indirect-tax aspects • Belgian VAT registration is needed, full (VAT) bookkeeping obliged • if goods are stored in regional warehouses in other EU countries, the Belgian EDC may need to register for VAT in those countries • supply of goods to Belgian, EU or non- EU customers by the Belgian EDC is in principle subject to VAT: - VAT exemption is possible for intra-EU supply of goods and export supplies to non-EU. - Local VAT is due if goods remain in Belgium. • VAT treatment of cross-border supplies depends on terms of supply. • to avoid prefinancing import VAT an import VAT deferral license (a so-called ET 14.000 license) can be obtained without any cash guarantee. Align customs value to the transaction price. • A ruling in respect of classification, origin and customs value is advisable. • cross-border authorizations and centralized customs clearance • Belgian input VAT can be deducted via the periodical VAT return • VAT credits are refundable on a quarterly basis, for “export” businesses license for monthly refunds is available 1 2 3 4 5 16
  • 17. It is crucial for us to be able to deliver quickly and efficiently the vehicles to the customers’ specifications to over 50 countries in Europe. The Port of Zeebrugge is an ideal base to do that.” Etienne Plas, spokesman for Toyota Motor Europe Read the full (his)story on Bose’s logistics in Flanders on page 20! 17
  • 18. SCENARIO 5 YOU NEED A FULLY-FLEDGED EUROPEAN HUB Status • Belgian legal entity • acting as a European holding and ­regional headquarter company (­holding EU subsidiaries and branches) • also treasury and operational activities can be performed Direct-tax treatments • Belgium offers attractive holding regime • taxable profit for regional headquarter activities and group services can be de- termined on a cost-plus basis • excess profit ruling is possible if profits of Belgian company result from group synergies • interest income on loans and other taxable income can be (partly) offset by Notional Interest Deduction (FY2013: 3%) on equity invested in the Belgian company • 95% exemption for qualifying dividends of subsidiaries • 100% exemption of capital gains on qualifying shares • exemption of profits of foreign PEs in Belgium • withholding tax exemption on repatriation of dividends to qualifying shareholders Indirect-tax aspects • holding and financial activities are ex- empt of Belgian VAT without input VAT credit, but the financial impact of non- recoverable VAT can be limited if set up as an active holding and an efficient “real use” methodology for input VAT deduc- tion is agreed with the VAT authorities • in respect of the “logistics” activities, see scenario 4 for the indirect tax aspects 1 2 3 4 5 18
  • 19. ForeignCo BelCo SUBs PEs Dividend: 0% Belgian Withholding Tax (WHT) NO WHT on remittance of profits Dividend: 0% intra- EU WHT Capital Loans AFFORDABLE LOGISTICS OPPORTUNITIES ABOUND Flanders is home to nearly 800 European Distribution Centers (EDCs), and although the region already has a long history in logistics, there is still ample capacity. The seaports of Antwerp, Zeebrugge, Ghent and Ostend have no congestion. On average, half a million m2 of logistics space are rented out yearly. This mainly concerns storage facilities of 5,000 m2 or more. In addition, Limburg, the easternmost of Flanders’ 5 provinces and ideally located on the crossroads with the Netherlands and Germany, is the best region in Europe for logistics activities. This statement was validated by the Cushman and Wakefield 2010 European Distribution Report. FULLY FLEDGED EUROPEAN HUB Flanders is situated in the very heart of Europe’s buying power and, in addition, we have excellent links to our customers in the EMEA region from there. This is the best location in Europe.” Luc Hooybergs, Nike ELC General Manager 19 NIKE’S LARGEST EUROPEAN DISTRIBUTION CENTER
  • 20. 20 FLANDERS AND BOSE, A MATCH MADE IN HEAVEN Specializing in high-end audio equipment for value seekers, Bose Corporation (US) has been synonymous with quality and performance ever since its inception in 1964. Striving for excellence in products as well as business and marketing potential, the company was looking for opportunities to expand its reach in Europe. Setting up office in Flanders in 1993 marked the beginning of a unique success story that is still going on today. The long-term relationship between Bose and Flanders is fairly unique. Over the past two decades, the company has gradually grown its presence in the town of Tongeren in Flanders from a modest distribution center to its European operational headquarters, going through virtually every scenario described in this guide in the process. CENTRALIZE AND CONQUER Actually, the abolition of the European borders was Bose’s cue to reorganize its logistics network and ensure further growth”, director of operations Gerjan Meerman explains. According to a study conducted by PriceWaterhouseCoopers, centralizing our European distribution center would boost customer satisfaction in the region and make us more efficient.” As a newly appointed logistics manager, Meerman’s remit was to turn theory into practice by setting up a central distribution center in Europe. Meerman: “The first, and most important question was: ‘Where?’ We ended up with a longlist of eleven places, which was reduced to three after initial research and talks with the local authorities. Interestingly, these ‘nominees’ were all located in Flanders (Belgium). It just turned out that they offered the best conditions in terms of land price, labor, logistics and tax incentives.” In the end the decision was made to establish the center in the industrial area of Tongeren. “From the get-go, we have had an excellent relationship with the town council and the government. Apart from the necessary facilities – like fiber optic cable – we got a lot of help from the authorities to get through the administrative process, not to mention the favorable withholding tax and special ruling we enjoyed. In a relatively short space of time, we were ready to go and, in 1995, the first commercial shipment was dispatched. All stock from the Netherlands had already been moved.” In 1995, Bose made further enhancements to its logistics process and the sales office in Ternat (Flanders) moved to Tongeren as well. In subsequent years, e-commerce started to take off. “In 2004, we had to further expand our capacity”, Meerman elaborates. “One year later, all of our European operations – including our DotCom office and repair center – were centralized there. In the end, it was just the most logical thing to do in terms of cost-benefit and long-term growth. Our relationship with Flanders and the local authorities has been excellent over the years, and we look forward to expanding our business in the region even further in the future.”
  • 21. SETTING UP YOUR BUSINESS IN FLANDERS? PIECE OF CAKE! It only takes 3 days to set up a company in Flanders: • Flanders Investment Trade. SETTING UP IN FLANDERS. Overview of the issues involved in establishing a business in Flanders, from types of business entities, incentives, workforce to imports and exports, competition law, and environmental regulations. www.investinflanders.com/EN/publications • Flanders Investment Trade. GUIDE FOR FOREIGN EMPLOYEES WORKING IN BELGIUM. All the legal steps an expatriate has to go through before taking up employment in Belgium. www.investinflanders.com/EN/publications • For more information on FLANDERS’ PORT AND AIRPORTS, please check their websites: www.portofantwerp.be, www.portofghent, www.‌portofoostende.be, www.portofzeebrugge.be, www.brusselsairport.be, www.antwerpairport.be, www.ost.aero • For more info, details, testimonials and contact data, please visit us at www.investinflanders.com WANT TO KNOW MORE ABOUT DOING BUSINESS IN FLANDERS? DAY 1 Open a bank account and deposit the minimum start-up capital DAY 2 Use e-deposit to draw up the deed of incorporation and articles of association DAY 3 Your unique enterprise number has been activated 21
  • 22. To help you realize your ambitions, Flanders Investment Trade can rely on a vast network of private partners, universities, federal and regional agencies, federations, and clusters, who, each in their particular domain, can provide you with their expertise and professional support. Part of the service of Flanders Investment Trade is to bring you in contact with those organizations that match your plans, the scale of your project and your market approach. Ask your FIT investment officer for a list of partners who can help you turn your ambitions into a complete success. In particular, we would like to thank PwC for their contribution to this brochure. PwC firms help organisations and individuals create the value they’re looking for. We’re a network of firms in 158 countries with more than 180,000 people who are committed to delivering quality in assurance, tax and advisory services. Tell us what matters to you and find out more by visiting us at www.pwc.com. Pascal Janssens PartnerPwC Belgium T +32 3 259 31 19 pascal.janssens@pwc.be www.pwc.be 22
  • 23. 23 GUIDING YOU ALL THE WAY Whether you are just starting up or looking to expand your logistics operations, Flanders Investment Trade supports you all the way. That is our mission. We provide confidential information and support. Our experienced staff is happy to help you with your questions regarding multimodal infrastructure, site selection, legal aspects associated with setting up your business locally, investment subsidies, recruitment, and much more. We can also introduce you to the right decision-makers and to community life in Flanders. CLOSE TO YOU We have about 70 regional offices worldwide to assist you, free of charge, wherever you are. Contact us today. We will be delighted to help you. WOULD YOU LIKE TO KNOW WHAT FLANDERS CAN DO FOR YOUR COMPANY? Visit us at www.investinflanders.com Call us on +32 2 504 88 71 or email us at invest@fitagency.be. Please find your contactperson in Brussels or abroad here: For news hot off the press, follow us on Twitter twitter.com/InvestFlanders.
  • 24. beeld silhouet nog te ontvangen Gaucheretstraat 90 | BE-1030 Brussels | Belgium T +32 2 504 88 71 | F +32 2 504 88 88 invest@fitagency.be | www.investinflanders.com twitter.com/InvestFlanders www.linkedin.com/groups