Corporate tax: an overview of novelties in 2024

Corporate tax: an overview of novelties in 2024

February 2024 - The start of a new year always has a number of tax novelties in store. In 2024, too, you can expect a number of changes in corporate tax. Which changes should you take into account?

Statutory filing deadlines

As is its annual custom, the FPS Finance informs taxpayers of the tax return filing deadlines. To provide additional legal certainty, these deadlines are aligned for the taxable periods linked to the assessment years 2024 onwards. The statutory filing deadlines for companies are as follows:

  • General rule: Last day of the seventh month following the end of the book year.

  • Corporate tax:

    * Legal entity tax

    * GNI (legal persons):

    End of period 31 December. Total for the period and in February. Last day of the seventh month following the end of the book year.

  • Annual impact on effectiveness: No later than 15 July of the year following the end of the reference period.

Mandatory disclosure of rental fee paid on corporate income tax return

From the assessment year 2024, there will be a mandatory notification for companies renting real estate or holding a right of superficies, emphyteusis, usufruct or another right of use in rem. Does your company pay rental fees or fees for business rights to individuals, NPOs or legal entities and does not receive an invoice for this? Then, you must add an attachment to your VAT return so that the fees paid remain qualified as professional expenses. This attachment includes the identification of the lessor or provider of the right of use in rem, the address of the property and the amount of the (rental) fees granted.

Investment deduction percentages update

Through the investment deduction, your company can receive tax subsidies for certain investments. For 2024, the following percentages apply:

INVESTMENTS DEDUCTION

Digital investments: SME 20,5% - Other companies 0%
Patents: SME 20,5% - Other companies 20,5%
Energy-saving investments: SME 20,5% - Other companies 20,5%
Green investments: SME 20,5% - Other companies 20,5%
Smoke extraction or ventilation systems: SME 20,5% - Other companies 20,5%
Security: SME 27,5% - Other companies 0%
Packaging reuse: SME 0% - Other companies 3%
Sea vessels: SME 30% - Other companies 30%
Green trucks: SME 36,5% - Other companies 36,5%
Other investments: SME 8% - Other companies 0%
Spread deduction green investments: SME 27,5% - Other companies 27,5%
Spread deduction other investments: SME 17,5% - Other companies 0%

From 1 January 2025, these rates will be adjusted to thematic investment deductions with fixed percentages.

New measures from programme law

In late 2023 - following the budget review - the programme law was passed. Some of the new measures:

·      The (popular) flexi-jobs scheme will be extended to 12 sectors.

·      Companies active in fruit and vegetable cultivation enjoy an exemption from withholding tax payments.

·      The CFC (Controlled Foreign Company) regime will be tightened. Under this regime, undistributed profits of controlled foreign companies are taxed in Belgium on behalf of the controlling Belgian company. From 2024, all passive income (interest, royalties, dividends?) will be taxable in the hands of the Belgian controlling parent company unless it can be shown that the foreign entity has sufficient substance (staff, assets, real economic functions).

·      The annual tax on credit institutions, collective investment undertakings and insurance companies is now a 100% disallowed expense.