Reveries of a Human

Welcome to Belgium. Would you like to opt-out of paying your fair share of taxes? Y/n

Management companies allow for such opt-out mechanism in Belgium.

Imagine you are an independent consultant expecting an annual turnover of EUR 120.000 and a net 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 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 wholly-owned management company. The company's only function is to act as an intermediary between you and your clients. You 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.

Congratulations, you saved yourself EUR 16.279 euro and reduced your effective tax rate by 14.73% (53,2% - 38,5%). You are in luck: these savings require no tax avoidance. 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 client.1 It is not surprising that, from 2019 to 2024, management companies doubled to an estimated 80.000.2

But what about ...?

The example is not even a best-case scenario.3 In reality, a management company could even be more beneficial as it could facilitate you qualifying for public benefits as a result of 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. A public debate exists as to the desirability of the tax regime that governs management companies. Affluent individuals in Belgium use management companies and have already started a public relations campaign in an attempt to confuse the general public. Management companies exist to facilitate tax planning; nothing more, nothing less. Proponents often cite limited liability as an important reason for their existence. This is a red herring: management companies could provide limited liability without simultaneously providing tax benefits.

Please help spread this message. If management companies continue to exist, government funding will be found elsewhere. As always, public infrastructure and services end up sacrificed at the altar of budgetary discipline, rather than the plaything of the rich. Luckily, the facts are on our side; let us make sure everyone knows them!

  1. https://www.dievandeboekhouding.be/

  2. https://www.tijd.be/netto/nieuws/belastingen/aantal-managementvennootschappen-rondt-kaap-van-80-000/10571633.html

  3. 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 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.