Doing Business in Belgium - RSM International

participation of 25% for at least 12 months. Dividends from a Hong Kong subsidiary
are not liable to any withholding in Hong Kong and qualify for the dividend exemption
in a Belgian holding company. Alternatively, a Belgian company that has a permanent
establishment can repatriate its profits tax free, even if the majority of the profit
consists of offshore income (including royalties and interest) that is tax exempt
in Hong Kong.
Belgium has also signed a new double tax treaty with the US. US source dividends are
exempted from US withholding tax provided the beneficial owner is a Belgian resident
company, owning directly or indirectly at least 80 percent of the voting power in the
company paying the dividends for a 12-month period prior to the dividend attribution
and satisfies an extensive limitation on benefits test. Belgian source dividends will be
exempt from Belgian withholding tax provided the beneficial owner is a US resident
company, owning directly at least 10 percent of the capital, and has been holding the
participation for a 12-month period prior to the dividend attribution.
Contact details RSM Belgium
1. Offices in Brussels
Lozenberg 22 b 3
B 1932 Zaventem
T +32 (0)2 720 09 08 - F +32 (0)2 720 52 62
interaudit@rsm-belgium.be
Chaussée de Waterloo 1151
B 1180 Brussels
T +32 (0)2 379 34 70 - F +32 (0)2 379 34 79
interaudit@rsm-belgium.be
Lozenberg 22 b 3
B 1932 Zaventem
T +32 (0)2 720 09 08 - F +32 (0)2 720 52 62
interfiduciaire@rsm-belgium.be
Lozenberg 22 b 3
B 1932 Zaventem
T +32 (0)2 720 09 08 - F +32 (0)2 720 52 62
intertax@rsm-belgium.be
Chaussée de Waterloo 1151
B 1180 Brussels
T +32 (0)2 379 34 70 - F +32 (0)2 379 34 79
interfinance@rsm-belgium.be
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DOING BUSINESS IN BELGIUM
DOING BUSINESS IN BELGIUM
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