International tax2025-09-23T11:55:32+02:00

International tax

Doing business internationally offers many opportunities, but also brings additional tax obligations. We help you comply with regulations and optimize your international activities for tax purposes.

What is international taxation?

Active in several countries? Then you must not only comply with Belgian tax law, you must also take into account local tax obligations, double taxation treaties and European and international reporting rules.

This includes sending staff abroad, providing cross-border services or transferring your production abroad. A well thought-out tax strategy is crucial. We advise you with respect to the optimal structure of your foreign activities and transactions.

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When do you need international tax advice: some examples

  • Cross-border dividends, interest or royalties
    Do you receive foreign dividends, interest or royalties? Under certain conditions, a foreign withholding tax exemption or reduction applies. If your Belgian company pays dividends, interest or royalties abroad, double taxation treaties determine the extent to which Belgian withholding tax is due.

  • Cross-border activities and foreign investments
    Are you planning an acquisition or setting up a new entity abroad? If so, you need to be mindful of local and international tax rules. For example, you may have to pay an exit tax when transferring your company’s headquarters abroad.

  • Global mobility
    Attracting new employees abroad? Or send Belgian employees abroad? These international regulations contain both opportunities and pitfalls. We ensure that you are prepared at the start.

Our services

International tax

When doing business across borders, not only the Belgian tax rules apply, but also the local tax laws of other countries. Our experts closely monitor the relevant legislation and ensure that your company complies with all obligations. If useful, we put you in contact with local experts. Are you starting up activities in Belgium as a foreign entrepreneur? Then we can assist you with the start-up formalities and later follow-up.

Tax compliance

Each country has its own tax rules. We support you in complying with all tax compliance, from corporate tax to withholding tax. Through a tax scan, we analyze whether you qualify for certain exemptions and optimizations.

Advice on permanent establishments

Staff, office, warehouse or machinery abroad? Or is your foreign company operating in Belgium?
If so, there may be a “permanent establishment,” which entails additional tax obligations. Through a PE analysis (“permanent establishment analysis”), we determine whether this is the case. We help you on your way to a market-based profit allocation and provide a clear view of your obligations.

Transfer pricing

Is your company part of an international group with cross-border transactions? If so, you must follow the rules around transfer pricing in intra-group transactions and work on market-based terms.

Our benchmarking studies are a useful tool in this regard. We look at where optimizations are possible and help you develop and implement a transfer pricing model, whether or not documented in an internal transfer pricing policy. In case of changes in your supply chain, we examine whether an update of your transfer pricing policy is necessary.

Why tax advice on transfer pricing?

Transfer pricing is gaining in importance: rules are becoming stricter and tax audits more frequent. Significant sums of money are usually involved between group companies, so corrections in a tax audit can have significant financial consequences.

Transfer pricing is also subject to strict documentation rules. Our experts support you in the preparation and timely submission of your transfer pricing documentation (local file, master file, CbC report).

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International network

As a member of Baker Tilly International, we can call on an extensive international network. For international tax issues, we thus bring you into contact with local experts.

Frequently asked questions regarding international tax advice

Can I move my company’s registered office abroad?2025-09-10T11:30:41+02:00

Thanks to the double taxation treaty between Belgium and Spain, it is possible to avoid double taxation in many cases.
In practical terms, the treaty stipulates that the country where the property is located (in this case, Spain) has the right to tax the income. Belgium may not tax this income again – except in specific cases under the “exemption with progression” rule.

What are the most important international reporting rules?2025-09-10T11:19:50+02:00

Larger international groups in particular (consolidated turnover exceeding EUR 750 million) must comply with various reporting rules within an international framework.
Examples include

How is foreign income taxed?2025-09-10T11:17:04+02:00

Belgian companies must declare their worldwide income in their Belgian corporate income tax return.

To avoid double taxation, whereby the same profit is taxed in two countries, Belgium has concluded double taxation agreements with various countries. Based on these agreements, income that has already been taxed abroad is usually exempt in Belgium.

When do I have a permanent establishment in Belgium?2025-09-10T11:29:34+02:00

Based on the relevant double taxation treaty, a foreign company may have a permanent establishment in Belgium:

  • If it has employees on a Belgian payroll who also actually work in Belgium. In that case, we refer to a ‘personnel’ permanent establishment.
  • If there is a place of business in Belgium where the activities are carried out. This could be an office, warehouse, storage space (whether rented or purchased) or a construction site. This is referred to as a ‘material’ permanent establishment.

We conduct an analysis to determine whether the conditions for a permanent establishment or a Belgian establishment are met and whether the company must comply with tax formalities in Belgium.

Take the first step toward growth today.

Our financial experts are ready to guide your business in a changing world. We provide solutions that work, now and in the future.

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