Are you starting logistics operations in Flanders or Europe? Below is the 5th of 5 possible business scenarios – ranging from a representative office to a fully-fledged international distribution center – for structuring your logistics activities.
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Fully-fledged European hub (holding, regional HQ, treasury)
Flanders is situated in the very heart of Europe’s buying power. In addition, we have excellent links
to our customers in the EMEA region from here. This is the best location in Europe.
Kurt Van Doninck
General Manager, Nike Logistics Europe
- Belgian legal entity.
- Acting as a European holding and regional headquarter company (holding EU subsidiaries and branches).
- Treasury and operational activities can also be performed.
- Belgium offers attractive holding regime.
- Taxable profit for regional headquarter activities and group services can be determined on a cost-plus basis.
- Excess profit ruling is possible if profits of Belgian company result from group synergies.
- Interest income on loans and other taxable income can be (partly) offset by Notional Interest Deduction (FY2016: 1.131%) on equity invested in the Belgian company.
- 95% exemption for qualifying dividends of subsidiaries.
- 100% exemption of capital gains on qualifying shares.
- Exemption of profits of foreign PEs in Belgium.
- Withholding tax exemption on repatriation of dividends to qualifying shareholders.
- Holding and financial activities are exempt from Belgian VAT without input VAT credit, but the financial impact of non-recoverable VAT can be limited if setup as an active holding and an efficient “real use” methodology for input VAT deduction is agreed upon with the VAT authorities.
- With respect to the “logistics” activities, see scenario 4 for the indirect tax aspects.