FSI Tax Alert (06/11/2013)
New administrative circular letter sheds some light on the amended article 19bis ITC
The Belgian tax authorities recently issued an administrative circular letter (Ci.RH.231/629.328, dated 25 October 2013) that provides some guidance on the various amendments brought to article 19bis ITC (the so-called “Belgian TIS”) since the law of 21 December 2009.
This circular letter had been expected for a long time by the sector because of the many uncertainties related to this provision’s application. So far, only one circular letter (Ci.RH.231/579.253) on the subject matter had been issued.
Essentially, the Belgian TIS aims at taxing Belgian resident individuals on (part of) the proceeds received upon exit from investments funds (irrespective of where the funds have been established and whether the funds are transparent or not for Belgian tax purposes) that (in)directly invest a certain portion (currently set at 25%) of their assets in qualifying debt claims.
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