Welcome to Belgium. Would you like to opt-out of paying your fair share of taxes? Y/N
The existence of such an opt-out mechanism seems absurd but is an unfortunately reality in Belgium due to existence of management companies.
Let us imagine you are a single independent consultant who expects to realize an annual turnover of EUR 120.000, resulting in a profit of EUR 110.500 (low cost structure). What are your options?
I wish to pay my fair share of taxes.
You perform your activities as an independent without management company. You will pay EUR 58.822 to the Belgian government (income tax + social contributions), resulting in an effective tax rate of 53,2%. This tax rate would also apply on any additional profit you realize, regardless of the amount.
For the underlying calculations, click here.
I do not wish to pay my fair share of taxes.
You perform your activities through a management company which you fully own. The company's sole function is to act as an intermediary between you and your clients in order to optimize your tax bill. You will pay EUR 42.543 to the Belgian government (corporate income tax + VVPRbis), resulting in an effective tax rate of 38,5%. This tax rate would also apply on any additional profit you realize, regardless of the amount.
For the underlying calculations, click here.
You just saved yourself EUR 16.279 euro and reduced your effective tax rate with 14.73% (53,2% - 38,5%). Surely, such immense savings require dodgy tactics? Well, no, not at all! Setting up a management company only requires a visit to an accountant and public notary (one-time expense of EUR 4.000). This is such a common practice in Belgium that some accounting firms only serve this type of clients.1 It is not surprising that, from 2019 to 2024, the amount of management companies doubled to an estimated 80.000.2
But what about ...?
The above example is inherently simplified but the benefit is already calculated based on very pessimistic assumptions.3 In reality, a management company structure is often even more beneficial as you could qualify for public benefits due to your low labor income (as you receive your income through dividends - don't ask). Moreover, management companies are frequently filled with inflated tax-deductible expenses ('business' diners in Michelin starred restaurants on Friday evening, high-end cars, secondary homes, ...).
What can we do?
Belgium has one of the highest budget deficits in the EU. The Belgian government is currently contemplating adjustments to the regime of management companies. It is extremely likely that any changes to this regime will be marginal at best, but will give the impression of a real reform. Why? The most affluent, well-connected people in Belgium use management companies. They already started a public relationship campaign in an attempt to confuse the general public. Management companies exist to facilitate tax planning, which also explains why such companies barely exist in neighboring countries (where they do not provide any tax benefit).
If you can, please help spread this message. If management companies continue to exist, the money will have to be found elsewhere. As always, it is public infrastructure and services which end up being sacrificed at the altar of 'budgetary discipline', rather than the plaything of the rich. Luckily, the facts are on our side, so let's use them.
https://www.tijd.be/netto/nieuws/belastingen/aantal-managementvennootschappen-rondt-kaap-van-80-000/10571633.html↩
For example: the applied corporate tax rate is 25% (instead of the 20% reduced rate which most management companies apply). The example is also based on the VVPRbis-regime (18% rate) instead of the VVPRter-regime (15% rate). In the end, the veil of complexity is a fundamental feature to allow proponents to defend that management companies do not result in any meaningful tax benefit. Should you have any doubt, perhaps a calculator published on the website of an accounting firm which boasts about the amount of savings might convince you: https://www.dievandeboekhouding.be/wat-is-een-managementvennootschap. It is in Dutch but just fill out your monthly gross wage in "Maandelijks brutoloon" and you will receive the estimated benefit in a bright green box at the bottom.↩