Belgium’s economy has a widely diversified industrial base, which benefits from the country’s highly developed transportation infrastructure and government support for open trade and investment. Belgium is heavily reliant on world trade, with the export of goods and services the largest contributor to GDP.
The regulatory environment in Belgium is highly efficient, and its unique tax regime offers several advantages, such as notional interest deductions. Belgium is also gradually reducing its corporate income tax rate to 25% by the 2021 tax year. Moreover, Belgium’s central geographical location and efficient transport infrastructure make it an ideal logistical base.
The Belgian banking system is highly sophisticated with minimal regulatory requirements. More than half of banking transactions are international due to the extent of foreign business conducted in Belgium. The country also has an extensive tax treaty network.
In recent years, Sino-Belgium bilateral ties have deepened, with China becoming Belgium's most important trading partner in Asia. Trade between the two countries tends to focus on agriculture, transportation and high-value added products.
What solutions are available in Belgium?
|Treasury Centres||A centralised treasury is one way to reduce the tax burden, centralise risk management, improve liquidity and enhance yield on cash.|
|Interest Optimisation||Maximise your interest yield from for your balances held with the bank.|
|Notional Pooling||Cash balances in different accounts are notionally offset to derive the net balance, which is then used to calculate interest.|
|Sweeping/ Zero Balance Account (ZBA)||ZBA are checking accounts with zero balances where funds are physically swept to eliminate excess balances and maintain greater control over disbursements.|
|Intercompany loans||Similar to bank loans, intercompany loans refer to lending between entities within the same group.|
Corporate Treasury in Belgium
Belgium is ranked as one of the top 25 most competitive economies in the world and was one of the founding members of the European Union. Here, we highlight some of the key benefits relevant to treasury and cash management in Belgium.
Financial Market Development
- The World Economic Forum ranks Belgium 24th in the world for its financial system in The Global Competitiveness Report 2019.
- It ranks Belgium 60th in the world for the soundness of its banks, while it rates it 23rd for market capitalisation as a percentage of GDP and 31st for venture capital availability.
- Belgium has excellent business infrastructure, a highly educated multilingual workforce and a sound legal environment.
- There are no foreign exchange controls in Belgium.
Sophistication of Banking Systems
- There are more than 100 banks and representative offices operating in Belgium, the majority of which are branches or subsidiaries of foreign banks. The sector is dominated by four large banks, namely ING Belgium, Belfius, BNP Paribas Fortis and KBC.
- Belgium's foreign exchange market has an average daily turnover of US$36 billion (Bank for International Settlements Triennial Central Bank Survey 2019).
- Belgium has a well-developed debt market with both government and corporate bonds widely available. Outstanding debt securities stood at USD724 billion at the end of the first quarter of 2020.
- The banking industry is regulated by the National Bank of Belgium and the Financial Services and Markets Authority. As a eurozone country, it is also covered by the Single Supervisory Mechanism.
- The corporate income tax (CIT) rate is 29%, plus a 2% crisis tax, giving an effective rate of 29.58%. CIT will be cut further to 25% in the tax year 2021 (financial year ending 31 December 2020) onwards, and the crisis tax will be abolished.
- For small-and-medium-sized enterprises (SMEs), the first bracket of EUR100,000 of income is taxable at 20% plus a 2% crisis tax, giving an effective rate of 20.4%. For the tax year 2021 onwards, the crisis tax of 2% will be abolished.
- Companies with taxable profits of more than EUR1 million face a minimum tax base through the limitation of some deductions. Certain deductions, such as current year tax losses, are fully deductible, while others, such as tax losses carried forward, can only be claimed for the amount of up to 70% of profits over EUR1 million.
- Resident companies are taxed on their worldwide income, whilst non-resident companies are taxed on Belgium-sourced income. There is no branch profits remittance tax on the remittance of profits to the head office by the branch of a foreign company.
- The standard rate for Value Added Tax (VAT) is 21% with certain goods and services qualifying for lower rates of 0%, 6%, 12% or are VAT-exempt.
- Capital gains on the disposal of qualifying shares are fully tax exempt, subject to meeting certain conditions. If the capital gains arise from the disposal of qualifying shares without meeting the one-year holding requirement, such gains shall be taxable at 25.5%. For non-qualifying shares, capital gains will be taxed at 29.58%, falling to 25% in the tax year 2021.
- Interest income is taxed as corporate income. Interest expenses are generally tax deductible, but only up to a level of 30% of the taxpayer’s fiscal EBITDA or EUR 3 million, whichever is higher. Borrowing costs above this level can be carried forward for an unlimited period of time. Taxpayers belonging to the same group also have the option to transfer unused EBITDA capacity to other member companies under certain conditions. The old thin capitalisation rule, under which interest payments in excess of a 5:1 debt-to-equity ratio are not tax deductible, continues to apply to interest payments to tax havens.
- Stamp duty is applicable on transactions relating to public funds that are concluded or executed in Belgium, however, exemptions are available.
- Withholding tax (WHT) on dividends and interest is typically charged at 30% to both resident companies (with some exceptions) and non-resident countries where no tax treaty is in place. Where a tax treaty is in place and the non-resident can provide a Certificate of Residence, rates range from 0% to 25% on dividends and interest.
- Belgium has tax treaties with more than 95 countries and territories.
- Belgium is a signatory to the Organisation for Economic Co-operation and Development’s Multilateral Competent Authority Agreement, through which information is exchanged between tax administrations, to provide a single, global picture on some key indicators of economic activity within multinational enterprises.
Benefits for Regional Treasury Centres
- Belgium is growing in popularity as a location for shared service centres, with the government naming the development of this sector as a key priority.
- Cash concentration and notional pooling are available in Belgium on a domestic and cross-border basis, but each group within a company must be treated as a separate legal identity, which can have tax implications.
- Belgium is a member of the pan-European TARGET2 real-time gross settlement system.
- Belgium has one of the most extensive tax treaty networks in the world.
- Belgium is a eurozone country with trading hours that overlap with Asia, Europe and North America.
- There are 85 banks operating in Belgium, of which 32 are under Belgium law. The majority of foreign banks are from the neighbouring countries of France, the Netherlands and Luxembourg. There are also 20 representative offices of foreign banks in Belgium.
- Due to its centralised location in Europe and with Brussels being the home for the main European Union (EU) institutions, Belgium's banking sector benefits from a diverse, international presence of financial institutions.
- The four leading banks are BNP Paribas Fortis, KBC Bank, Belfius Bank (state-owned) and ING Bank Belgium, and in total make up 68% of the country’s total banking assets.
- The National Bank of Belgium (NBB) designated eight banks as ‘domestically systematically important’, and this group accounted for 90% of total banking system assets in 2016.
- Residents may hold foreign and domestic currency accounts both domestically and overseas. Domestic currency accounts are fully convertible into foreign currency.
- Non-residents may hold foreign and domestic currency accounts both domestically and overseas. Domestic currency accounts are fully convertible into foreign currency.
- Interest is available on current accounts and term deposits.
Legal and Regulatory
- The NBB is an autonomous institution and a member of the European System of Central Banks (ESCB).
- The European Central Bank (ECB) supervises banks within the eurozone that are regarded as 'significant' through the Single Supervisory Mechanism (SSM). Other 'less significant' banks are supervised by the national central bank, such as the NBB.
- Belgium is one of the founding members of the EU.
- Belgium has anti-money laundering and counter-terrorism financing legislation in place, and follows EU anti-money laundering directives.
- There are no foreign exchange controls in place.
- A company is resident if it is registered in Belgium or its main management activity or location of effective management is carried out in Belgium.
- Belgium has set up a financial intelligence unit, the Financial Information Processing Unit (CTIF-CFI), which is a member of the Egmont Group.
On 13 January 2018, the revised Payment Services Directive (PSD2) became law across all EU Member States. A revision of the initial PSD adopted in 2007, PSD2 updates and enhances the legal framework for payment systems across the European Economic Area (EEA) single market, to be supervised by the European Banking Authority. Supplemental regulatory technical standards are also being rolled out, from March 2018 to September 2019, to address issues of authentication, monitoring and API (application programming interface) standardisation.
The main objective of PSD2 is to provide enhanced consumer security in the developing financial technology (fintech) environment i.e. for electronic payments such as mobile payments, credit transfers, online payments and direct debits.
- Prohibition of surcharges on credit/debit card payments.
- Imposition of strict security requirements including the protection of financial data.
- Increased competition between European payment service providers.
- Greater consumer rights such as ‘no questions asked’ refunds on direct debits in euros.
(Trans-European Automated Real-time Gross Settlement Express Transfer system)
The eurozone's Real-time Gross Settlement (RTGS) system
|STEP1||Pan-European net settlement system|| |
|STEP2||Pan-European Automated Clearing House (ACH)|| |
(Centre for Exchange Clearing and Settlement Mechanism)
Automated multilateral network settlement system
Single Euro Payments Area
Pan-European payment infrastructure
SCT InstSEPA Instant Credit Transfers
|Pan-European instant payments system|| |
SDDSEPA Direct Debits
|Pan-European direct debit system|| |
|RT1||Pan-European real-time EUR credit transfer system|| |
|EURO1||Pan-European RTGS-equivalent net settlement system|| |
- Credit transfers are all automated in Belgium and are the most important form of cashless payment, representing 36.5% of volume and 96.9% value of all cashless payments in 2019.
- High-value and urgent credit transfers are settled through TARGET2_BE in real time.
- Low-value and non-urgent SEPA transactions are cleared same or next day through CEC CSM.
- Used for payroll, supplier and third-party payments.
- The SEPA Credit Transfers (SCT) scheme is used for retail transactions and is available for urgent and high priority payments (no maximum threshold) within the SEPA.
Direct Debit (auto debits)
- Used for low-value, regular transactions such as utility bills.
- CEC CSM clears all SEPA direct debits.
- The SEPA Direct Debit (SDD) scheme is used for urgent and high priority retail payments (no maximum threshold) within the SEPA. It is mandatory for all banks in the eurozone to offer SDD facilities and banks outside of the eurozone are required to accept SDD transactions. High value transactions of more than EUR500,000 can be processed through TARGET2.
- Direct debits in Belgium account for 11.3% and 1.7% of cashless payment volume and value respectively.
- Payment cards are the most popular form of cashless payment, especially debit cards used with contactless (touch-and-go) systems.
- Card payments make up the majority of cashless payment volume, accounting for 50.2% in 2019, but only 1.2% of cashless payment value.
- Mister Cash (Bancontact) is the most common debit card in use (accounting for about 95% of debit cards in circulation). The card is linked to the user's Belgian bank account and also has a Maestro function.
- The main payment card brands (excluding Mister Cash) are Visa and MasterCard, with American Express and Diners Club credit cards also in circulation. All payment cards are SEPA and EMV-compliant.
- Card payments are usually processed through Atos Worldline card processing centre, which is linked to the CEC CSM system.
- Charges are no longer incurred for card payments made through Bancontact, Mastercard and Visa.
- Reloadable prepaid payment cards are available and are offered by many of the banks such as the Hello prepaid card and Moneytrans.
- The financial technology (fintech) sector is dominated by services linked to digital payments, due to Belgium’s established presence in the payment industry (SWIFT and Euroclear are headquartered there) and the fast adoption of online transactions.
- The government does not have regulation in place specifically focused on the fintech sector. However, the NBB and the Financial Services and Markets Authority (FSMA) is supportive of developments in technology innovation and the financial sector, and manages applications within the existing regulatory framework.
- The FSMA has launched a fintech portal on its website as a networking platform for fintech companies to interface with the authorities and other industry players.
- The EU launched an ‘action plan on Fintech’ in 2018 that broadly sets out its approach, to be rolled out in due course. The areas of focus are: to encourage innovative business models; to support technological development in blockchain, artificial intelligence and cloud services; and to increase cybersecurity and protect the integrity of the financial system.
- Online transactions have been widely adopted, with payments mainly done using payment cards or online banking. A popular local payment platform, Ogone, offers a variety of payment methods, such as online banking or credit cards. Other global digital payment systems with a market presence are PayPal, Android Pay and Sofort.
- Belgium’s e-commerce market is worth EUR10 billion, of which 15% is mobile commerce. Online spending is a growing segment and made up 20% of all retail spending in 2019.
- Cards are used for half of online payments, with Bancontact debit cards being used for 68% of online purchase volume and 30% of value in 2018.
- Mobile wallets have had a relatively slow uptake, being used for 17% of e-commerce transactions. Bancontact, the most popular mobile payment app, has merged with another popular mobile app, Payconiq, with the aim of producing a unique, unified payment app.
- There is an active market in cryptocurrency, although the FSMA has not issued any regulations, other than advising extreme caution.
- A recent court ruling in Belgium classified bitcoin activities as ‘speculative’, and thus any profits earned were liable to 33% capital gains tax.
- The EU’s overall view of bitcoin is that “no member state can introduce its own currency”. Cryptocurrency exchanges are legal, depending on the country, and should be operated under the Anti-Money Laundering Directive, according to the European Commission.
Cash, Cheques and Money Orders
- Cash continues to be the predominant form of payment, due to a combination of an overabundance of ATM machines in Belgium and a lack of digital payment systems at smaller shops and other service providers.
- Cheques usage is in rapid decline, in line with the phasing out of Eurocheques and the rapid increase in electronic transactions.
- Belgian banks are imposing charges to discourage cheque usage as the payment system will not be part of SEPA.
- If cheques are used, it is usually for one-off, high-value payments such as property purchases.
- Irregular cheques are truncated into electronic images and processed as credit transfers. Foreign or high-value cheques (of more than EUR25 million) are processed manually and cleared bilaterally between banks.
- Low-value cheques are cleared through CEC CSM.
- Money orders are available through postal orders, for domestic or international transfers, or Western Union and Moneygram for international services.
1 (Main) reduced and zero-rated VAT for certain goods and services
2 (Progressive) max rate on incomes over EUR322,500
3 (Progressive) max rate on incomes over EUR39,660
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Sources: World Economic Forum, PwC, Bank for International Settlements, the National Bank of Belgium, The Heritage Foundation, OECD, DBS, TheBanks.EU, European Banking Federation, European Central Bank, Association for Finance Professionals, Ecommerce News Europe.
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