Company contribution deferral for foreign companies in Belgium

Belgian internal law makes reference to a 'Belgian establishment.' This term applies for example to companies that hold stock in Belgium, or foreign companies that employ employees in Belgium. Yet, whilst this type of company is considered a Belgian establishment, it is not deemed a ‘permanent establishment’ in accordance with the double taxation treaty.

The income generated from your Belgian establishment is therefore not taxable, due to it being exempt as a result of the double taxation treaty. However, you are still obliged to submit a corporate income tax return on an annual basis. Since this tax return does not include a taxable base, it effectively constitutes a 'nil return.'

You will have to pay a company contribution as a result of this nil return. In 2020, the company contribution amount for a nil return was 347.50 euros. The contribution for 2021 is not yet known. This contribution must normally be paid prior to 1 July. However, the government made an exceptional decision to postpone the 2021 payment deadline to 31 December, 2021 due to the corona crisis.