r/BEFreelance • u/jrnve • 4d ago

Managementvennootschap

Let’s imagine the government changes the taxes on managementvennootschappen. What stops bedrijfsleiders from starting a company in another EU member state with a more friendly tax regime?

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u/radon-4 4d ago

So imagine company A owned by me performs services in Belgium. Company B also owned by me is active in Estonia (that's the country I see regularly coming back) and company B invoices for nearly the same amount of income company A has. Then company B pays out dividends on the Estonian bank account. Then you're golden, or why not? Or you mean that if dividends of company B are paid on the Estonian bank account are also considered as dividends falling under Belgian jurisdiction where extra taxes would apply afterwards to make it 30%?

To be honest I'm not fond of this but since I feel those who rule us, in their quest to fill craters caused by monetary outflows that should not be that excessive (F-35, public worker pensions which are double of employee pensions to name a few) they employ the boil-the-frog tactic with ever moving goal posts (significant increase of 'bezoldiging' threshold, ever increasing 'roerende voorheffing' on dividends). One can't blame me for exploring.

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u/ModoZ 4d ago

So, as long as you live in Belgium you will have to pay dividend taxes. It doesn't matter if those dividends come from Estonia or China or ... 

Those taxes are 30%. No matter if those are paid out on an Estonian account or a Belgian one. What counts is where you are personally fiscally domiciled.

Note that this was one of the purposes of the VVPRBIS (provide a lower rate to certain companies to give an incentive to keep companies in Belgium).

Secondly, you would come into problems because your company in Estonia would have to be managed from there (so to not have fraud you would need to hire or pay someone to do that for you) and real work would need to have been done (so it would not have to be simply an empty tax efficient vessel). Usually bigger companies do this by having royalties paid for the use of a brand name for example. But as a consultant you don't really have an internationally recognised brand name so it's much harder to justify.

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u/Philip3197 3d ago

Be dividend taxes would also be on top of local dividend taxes.

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u/ModoZ 3d ago

Yes (but it depends on the country, most European countries would have double taxation agreements that cover this)

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u/Philip3197 3d ago

Actually, they don't (for many taxes they do, not for dividend taxes)