In haar publicatie Global Opportunities for Relocation geeft BDO een overzicht van belastingen over de wereld. Hieronder leest u de situatie in Nederland, België en Luxemburg (het rapport is in het Engels). Klik hier om het volledige rapport te downloaden.
With a tax rate for individuals of approximately 50% on employment income and business profits, Belgium does not qualify as a low tax jurisdiction, although there are some tax incentives for Belgian resident individuals and the advanced tax ruling system can provide individuals with clarity and certainty on their tax liabilities/treatments.
International executives taking up employment in Belgium within an international group of companies may qualify for a favourable expatriate tax regime. The executive will be liable to Belgian personal income tax on their Belgian source income only.
Moving expenses and ongoing expenses (eg cost-of-living, housing allowances and school fees) may be reimbursed without tax liabilities, whilst share options granted by the employer before the executive becomes resident in Belgium are not subject to Belgian tax at the time of exercise.
In principle, capital gains on the sale of shares are exempt from tax, unless the capital gains derive from ‘speculative’ operations.
Whilst investment income is generally subject to tax at 30%, capital gains on portfolio investments are not taxable for individuals, except on a disposal of units in certain collective investment funds (“black funds” and funds holding more than 10% of its assets in debt instruments). Further, whilst Belgium has an inheritance tax regime, it does not levy wealth taxes or impose an exit tax charge for individuals leaving Belgium.
The Netherlands has traditionally been attractive for international companies. Nonetheless, it can also be attractive for private clients. In particular, for new residents with a foreign company, because of the uplift in base cost for capital gain tax for substantial shareholdings. Furthermore, the Netherlands has an extensive Double Tax Treaty Network.
Resident individuals are taxed on their worldwide income. Under the scheduler tax system, taxable income is grouped into three “boxes”. Income from (former) employment and dwellings (box 1) is taxed at progressive rates up to 51,95%. Income from substantial shareholdings (box 2), including dividends and capital gains derived from substantial shareholdings in resident and non-resident companies, is taxed at a flat rate of 25%. Income from savings and investment (box 3) is based on a weighted notional yield on net assets, taxed at a flat rate of 30%.
Inheritance and gift taxes are imposed if the deceased or the donor was a (deemed) resident of the Netherlands at the time of death or at the time of the gift or the ten years before (deemed residency). If a new resident of theNetherlands obtains an inheritance or gift from a resident of another country, this acquisition is therefore not subject to Dutch inheritance or gift tax.
Generally, employees who come from abroad incur additional expenses as a result of (temporary) working outside of their home country. In the Netherlands, these so-called extra territorial costs can be reimbursed tax-free to these employees. If certain conditions are met, it is also possible to apply for a so-called 30%-ruling. As a result, the employee will be deemed to incur 30% of their employment income as extraterritorial costs. Instead of reimbursing the actual territorial costs, the employer is then allowed to pay the employee a tax-free allowance that does not exceed 30% of the employee’s total remuneration.
In additional, international school fees can be reimbursed to the employee. This ruling, which is being shortened from eight years to five years from January 2019, is an incentive to attract foreign workers with specific expertise. An employee who has been granted the 30% ruling can also elect to be treated as a “partial non-resident”, whereby the employee is subject to Dutch income tax on specific sources of income.
Located at the heart of the EU, surrounded by Belgium, France and Germany, Luxembourg offers a high standard of living with social and political stability and a very low crime rate. It is a family friendly place to live. With a population of half a million people, its distinct characteristic is the high diversity of expatriate residents living and working in Luxembourg. Whilst, with a marginal income tax rate for individuals of approximately 45%, Luxembourg is not a low tax jurisdiction, some characteristics of its tax system make it really attractive.
Capital gains are not taxable where the asset has been held for more than six months. There is an exception for equity investments where the individual owns more than 10% of the company. However, new residents are able to benefit from an uplift in the base cost of their assets when they become resident, thus reducing any future net gain on the disposal of those assets whilst resident in Luxembourg.
Capital gains on portfolio investments are exempt from tax after a six month holding period. Only 50% of a gross qualifying dividend received by an individual is taxed in Luxembourg, with the other 50% exempt. In addition, foreign tax credit may be available for overseas dividends. Interest income is subject to a 20% final withholding tax in Luxembourg.
Whilst Luxembourg does not levy a net wealth tax on individuals, it does have inheritance tax. However, exemptions from inheritance tax are available where assets are left to lineal descendants (eg. parents to children). Gift taxes do not apply unless the gift is registered.
Klik hier om het volledige rapport te downloaden.