FSI Tax Alert (01/08/2013)
New circular letter on dividend withholding tax exemption for non-resident pension funds
Before the entry into force of the Royal Decree of 20 December 2012, all non-resident savers could – based on Art. 106, § 2 RD/ITC – benefit from a withholding tax exemption on Belgian source dividends (including income from so-called “missing coupons” under stock lending and repo arrangements) under the cumulative conditions that they were not engaged in a commercial activity in Belgium and were tax-exempt in their country of residence.
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