Does a more fiscally harmonized EU represent a challenge for Belgium in regards to its current

fiscal particularities?

ECON-S-305 – Questions approfondies d’économie européenne – Jorge Duran Laguna

Soweid Philippe, Van Camp Toon

Table of contents: Abstract: ................................................................................................................................................................................................ 1 I. Introduction ..................................................................................................................................................................................... 1 II. Tax evasion and on-going EU fiscal harmonization plans...................................................................................... 2 III. Fiscal singularities in Belgium ............................................................................................................................................ 5 IV. Effects of the EU fiscal harmonization plans on Belgium .................................................................................... 10 V. Conclusion ..................................................................................................................................................................................... 11 Appendices:........................................................................................................................................................................................ 12 Bibliography: ..................................................................................................................................................................................... 14

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Abstract This paper will attempt to describe and analyze one of the main problematics on the European level, fiscal harmonization, and will focus on the case of Belgium. We will study the new fiscal reforms that the European Commission has planned and the effects they will have on Belgium in regards to the fiscal particularities of the country. The goal will be to analyze whether these particularities can continue to exist or not in the likely situation that the EU manages to push forward its fiscal reforms. If they are adopted, Belgium will have to adapt to the new fiscal frame. Therefore, we will also study how Belgium could react in case these fiscal reforms were to be adopted.

I. Introduction In recent years, the European Union harmonization plans have managed to accomplish quite impressive achievements with, for example, the Single Market and the Banking Union programs which, even if their contents were not entirely applied, have been contributing to a more “unified” European Union. One of the sectors which did not manage to contribute to a more harmonized EU is the fiscal sector. Indeed, the divergences between certain countries in terms of corporate or personal taxation have been slowing down the attempts to reach a fully harmonized EU. Furthermore, these disparities cause many distortions in Europe with companies trying to transfer their profits to countries with a lower fiscal pressure, even if their real economic activity is not happening in this specific country. Today however, it is the topic on the front scene of the European political ambitions. In Belgium, there have been concerns about the consequences of the application of these fiscal harmonization reforms due to the fact that Belgium has some unique fiscal rules. What this paper will focus on is what the European Union has in mind in terms of fiscal harmonization plans and the conditions and consequences of these plans’ application in Belgium. The goals will be to determine whether or not the fiscal laws in Belgium enter the European criteria for a fiscal harmonization and how Belgium will need to react to increasing fiscal harmonization in the EU.

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II. Tax evasion and on-going EU fiscal harmonization plans

Fiscal harmonization has never been such a hot topic as it is today; indeed, it has been declared as being one of Jean Claude Juncker’s top priorities only mere days after he became head of the European Commission in 20141. Fiscal harmonization is important because heterogeneous and outdated fiscal laws in the EU have caused the emergence of fiscal gaps which allow companies to use BEPS2 (which stands for Base Erosion and Profit Shifting) in order to pay less, or no taxes. BEPS is thus a form of tax planning where companies use these fiscal gaps to shift profits from subsidiaries in a country where taxes are high to their subsidiaries in countries where there are little or no taxes to be paid, resulting in profits for the company but in losses in the form of non-paid taxes for the country where the economic activity took place. BEPS can also be achieved via interest deductions and other financial payments, indeed some countries have created preferential regimes which allow companies to, for example, deduce interests from their taxable income thus resulting in less overall taxes for the company. BEPS is thus facilitated by countries that compete with each other on a fiscal level by creating preferential regimes for companies in order to try to attract the most revenues to the country. This results in a race to the bottom between countries and thus the creation of plenty of opportunities for BEPS for the companies and subsequently in losses for the government of the EU member states. The importance of fiscal harmonization is further underlined by the fact that the European parliament has estimated that BEPS costs the EU member states between 50 and 70 billion euros annually3, this money could be employed to finance public projects, healthcare, education or to stimulate growth. In recent years, there are several steps that have been taken in order to further develop fiscal harmonization: mainly the BEPS Action Plan and the CCCTB, which effects and mains ideas are described below, can be considered as the most ambitious ones. 1 “Optimisation Fiscale : La Métamorphose de Jean-Claude Juncker.” Accessed May 15, 2016. 2 “About Base Erosion and Profit Shifting (BEPS) - OECD 3 “Nouvelles Mesures Contre L’évasion Fiscale Des Entreprises - Commission Européenne.”

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The BEPS Action Plan4: In 2013 the G20 endorsed the BEPS Action Plan which is made up of 15 key points that need to be addressed. The BEPS action plan has as a goal to create a more coordinated stance between EU member states against companies that use BEPS to pay fewer taxes. The three core pillars of the plan are to: Ensure fairer taxation in the EU: companies should pay taxes where they make

their profits; the BEPS action plan provides an “Anti-Tax Avoidance Directive” that contains legally binding measures in order to prevent companies from using some common tax avoidance schemes, thus ensuring that companies pay the taxes in the country where they perform the economic activity. It also contains a Recommendation that advises Member States on how to create a tax system that is impermeable to fraud or evasion.

Increasing tax transparency: this point is essential as companies use the heterogeneous and complicated tax treaties between countries or of a country in order to avoid taxes. Creating a clear, transparent framework for taxation in the EU member states will help detect cases of BEPS and avoid tax competition. The package has as goal to boost transparency on the taxes that companies pay or do not pay. This will be achieved through a revision of the “Administrative Cooperation Directive” where countries will be required to exchange tax information for the multinationals operating on their territory. This will help identifying risks of BEPS occurring and thus ultimately to prevent it.

Securing a level playing field: as tax avoidance is a global problem, it is important that other countries that are not part of the EU try to follow the same set of rules than the one the EU imposes on its member states. If other countries follow the same rules, BEPS will become very difficult even on an international level. The package contains a “Communication on an External Strategy for Effective Taxation” which aims to create a reinforced cooperation with countries outside of the EU in preventing tax evasion, to enhance EU measures that

4 “Commission Européenne - COMMUNIQUES DE PRESSE - Communiqué de Presse - Justice Fiscale: La Commission Présente de Nouvelles Mesures Contre L’évasion Fiscale Des Entreprises.”

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promote fair taxation globally, and to create a common approach in addressing cases of tax avoidance.

The action plan also assesses the risks of BEPS due to the emergence of the digital economy5. Indeed, due to the development of the digital economy it has been very easy for companies to establish themselves in a country where taxes are low and manage to have a high amount of sales in a remote market with the help of digital means. Companies can thus avoid paying high taxes while at the same time having access to numerous markets and gaining revenues in them. In order to counter this, one of the main goals of the action plan is to make sure that taxation will increasingly take into account the location where the economic activity has really taken place. If the measures presented in this action plan were to be adopted by the Member States, a very high level of fiscal harmonization will be achieved in the EU. Although countries and companies will have to adapt to be able to comply with these new laws, both will mostly benefit from these measures.

The CCCTB6: A second reform that has been pushed forward since 2011 is the implementation of the Common Consolidated Corporate Tax Base, abbreviated as the CCCTB. The CCCTB tries to address the problem of corporate taxation, and thus of fiscal competition, in the EU. The CCCTB is a single set of rules that would have to be used by all companies established in the EU in order to compute their taxable income. It would thus become much easier for the companies to pay their taxes because it would require less people to determine what is taxable and where, this will enable companies to cut costs. Multinationals would be able to submit only a single consolidated tax form for the entirety of their operations in the EU. The EU Member States will benefit from this reform due to the fact that they can keep their national corporate taxation rates, but will suffer from less fiscal competition and BEPS due to the fact that it will no longer be possible for countries to create preferential regimes for companies by allowing them to 5 OECD. Addressing the Tax Challenges of the Digital Economy, Action 1 - 2015 Final Report. OECD/G20 Base Erosion and Profit Shifting Project. OECD Publishing, 2015. 6 “Common Consolidated Corporate Tax Base (CCCTB) - European Commission.”

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reduce their taxable income and thus to “steal” businesses from other countries. . The project is taking a long time to implement as negotiations have stalled in the Council due to its massive size, but it will be relaunched in 2016 with the main differences that the CCCTB will be mandatory which will further increase its effectiveness and that it would be introduced progressively in a step by step process. Fiscal harmonization has thus become one of the highest priorities of the EU in the recent years. A fiscally harmonized EU would create huge benefits both for the Member States and companies established in the EU as it would hinder any possibility of BEPS for companies and render fiscal competition impossible. Several projects have been proposed by the Commission to work towards fiscal harmonization such as the BEPS action plan and the CCCTB. If these proposals were to be implemented most actors in the EU will benefit from them. Some however, will stand to lose from these reforms, notably the countries that have benefitted from the fact that fiscal competition has been an effective way to attract companies and thus revenues and jobs into the country. This is very important since it means that some countries will be opposed to the acceleration of fiscal harmonization due to the fact that their losses would likely outweigh the benefits.

III. Fiscal singularities in Belgium Now that the overall situation in the European Union has been enlightened, the rest of this paper will focus on the case of Belgium’s fiscal singularities and its effects on the competitiveness of Belgium in comparison with the other Member States. Does Belgium have special or unique fiscal laws that affect its fiscal competitiveness in the EU and if so, what are the contents of those laws? Are they against the principles of the EU and are they compatible with the harmonization plans we saw above? The goal is not to detect whether or not a certain tax rate is lower in Belgium than in another member state but to pay attention to fiscal rules or mechanisms that would create distortions in a fiscally harmonized EU.

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Notional interest deduction7: Also known as “fiscal deduction for risky capital”, the notional interest mechanism has been adopted in 2006 in Belgium, following the modification of the “coordination center” regime that the European Commission made mandatory for Belgium8. The main goal of the directive was to make funding by capital fiscally equal to funding by loans. The mechanism used is to create a fictional interest on the stockholder’s equities that he brings into the company. By doing so, the company can deduce its taxed earnings with this interest, which plays a role of a charge that diminishes the tax base without really “costing” anything for the company9. The rate of this fictive interest is settled by the Belgian authorities and is currently at 3.13% for the SMEs and 2.63% for the others. The Belgian government justifies the difference by its effort to promote the SMEs more than the big companies10. The objectives of this directive were honorable but the results are quite ambiguous and led to many controversies about whether or not it should be abolished. First of all, the biggest winners of this law are not the SMEs, in contrary to what the announced objectives were, but the big companies, and in particular the multinationals11. These companies are sometimes not even active, economically speaking, in Belgium. The goal of such procedures for the multinationals are to transfer some of its activities in Belgium, where thanks to the notional interest deduction, they pay less taxes before retrieving their remaining profits to the parent company in the form of dividends, which will not be taxed accordingly to the “Régime des revenus définitivement taxés”12. Among the companies benefiting the most of this mechanism, one can find a majority of foreign companies, such as ArcelorMittal (which deduced almost 1.6 billion € in 2011) or GDF Suez. What can also be said is that most of these companies are only proxies of their parent company and are not really participating in the economic activity of Belgium

7 Service Public Fédéral Finances (1992) Codes des impôts sur le revenu 1992, Version historique, Article 205bis – 205novies : Déduction pour capital à risque, Belgique. 8 Huez, J-M (2005), « Décision finale positive dans le dossier des centres de coordination belges », Competition Policy Newsletter 2005-1, State Aid. 9Service Public Fédéral Finances, « Déduction d’intérêt notionnel », Service Public Fédéral Finances > Entreprises > Impôt des sociétés > Avantages fiscaux 10 http://www.filo-fisc.be/Downloads/intnotionnels.pdf 11 http://www.lesoir.be/542482/article/debats/chats/2014-05-12/11h02-interets-notionnels-beneficient-davantage-aux-grandes-entreprises-qu-aux-p 12 http://www.droitbelge.be/fiches_detail.asp?idcat=11&id=597

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with less than a hundred workers for 15 companies of the 20 that benefited the most notional interests13. Now that the concept is explained, can one state that it is incompatible with the European treaties and its principles? The answer might be quite ambiguous. According to what the European Commission stated in a press release of 201214, in which they asked Belgium to grant the deduction for foreign real estate and permanent establishments as well as for Belgian ones, the concept itself of notional interest is not questioned by the commission, only the application was. With that being said, it is clear that this law provokes a distortion among the Member States. Indeed, a company based in a nearby Member State could create a “proxy” company in Belgium, which would own the equities and serve as a financing one to the “real” company. The proxy would lend the funds to the real company with the notional interest rate and would retrieve the benefits tax-free thanks to the “Régime des revenus définitivement taxés”. This would clearly be against the objectives of the European Commission, in terms of fiscal harmonization, due to the fact that the company would not be taxed where its economic activity actually takes place. Moreover, there has been complains by the United States about this mechanism15. They are not fond of the fact that the interests paid by American companies are almost tax-free thanks to the notional interests and the treaties between the two countries. In order to tackle this, they intend to tax 30% of these interests paid to a Belgian subsidiary. The pressure brought by this announcement might force Belgium’s authorities to handle the “notional interest issue” once and for all.

The excess profit scheme16 Applied since 2005 in Belgium, this fiscal rule has recently been declared illegal by the European Commission. The reasons invoked by the Commission were that the law was against the normal practice of Belgian company tax rules and that it was a violation of the arm’s length principle of the EU state aid rules and thus considered as unfair competition 13 http://www.lesoir.be/175362/article/economie/2013-01-31/arcelormittal-est-l%E2%80%99entreprise-qui-plus-profit%C3%A9-des-int%C3%A9r%C3%AAts-notionnels 14 http://europa.eu/rapid/press-release_IP-12-61_en.htm 15 http://trends.levif.be/economie/politique-economique/les-usa-vont-ils-faire-bouger-le-federal-sur-les-interets-notionnels-et-l-impot-des-societes/article-normal-468023.html 16 http://europa.eu/rapid/press-release_IP-16-42_fr.htm

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towards companies that are not benefitting from the rule and towards established in other Member States. A brief description of the rule will help to understand the European Commission’s decision. The concept of the excess profit scheme can be illustrated as follow: if a multinational company’s economic activity takes place in Belgium, its profit will be taxed taking into account the fact that the multinational status of the company gives “excess profit” to the company and that this excess profit should not be taxed in order to prevent double taxation. In order to compute the tax base of these companies, the Belgian fiscal authority will look at how much profit a stand-alone company would make on average in a comparable situation. The result of this law was a reduction of the tax base for the concerned companies by more than 50%. Therefore, the European Commission required Belgium to put on hold the rule since 2015 and is waiting for the removal of the excess profit scheme from the “Code des impôts sur le revenu”. Furthermore, they enquired Belgium to recover the unpaid taxes from at least 35 companies that benefitted from the scheme. In total, the Commission asked Belgium to recover about €700 million from the companies that profited from the scheme in order to reestablish a competitive playing field. As the European Commission stated in its press release, the scheme is against the EU principles in terms of fair fiscal competition. The objective of preventing double taxation was judged to be irrelevant. In fact, the scheme led more to a “double non-taxation” mainly for two reasons. The first reason is that in order to prevent double taxation there should be a contact between Member States, exempting a company from taxation in a country should only be allowed after information was received from another country that that company has already been taxed. In this case the creation of this law was a unilateral decision from the Belgian government and cooperation between Member States was completely inexistent. The second reason is that companies did not have to prove that they were subject of double taxation or that there was a risk that double-taxation could happen to them in order to benefit from the excess profit scheme. This led to a situation where some multinational companies benefitted from this scheme and obtained an unfair competitive advantage compared to other stand-alone competitors.

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Patent’s income deduction17 In effect since 2007, this regime is one of Belgium’s attempts to encourage companies to invest in innovation and research and development activities18. The concept is quite simple, a drastic deduction of 80% of the taxable revenues of the activities linked directly to the patent. The scope for its application is quite wide as well since the patent does not have to be developed by the company but it can also have been bought. If it has been developed by the company, it must have an R&D activity, in Belgium or abroad, which should be responsible for it. And if the patent was bought, the company should have brought an improvement to it. It can be noted that this kind of fiscal rule is not an exception in Europe, even among EU Member States19. Indeed, Ireland was the first country in Europe who tried to foster innovation by creating what is now called a “patent box”. Belgium and the Netherlands followed the lead by creating their own, different, regime and Luxembourg did the same a bit later. Despite the popularity of such regimes, the OECD and G20 took action against it with the BEPS project’s action 5 “Countering Harmful Tax Practices More Effectively, Taking into Account Transparency and Substance”20. In this action, they intend to identify and tackle the patent boxes that they will judge as harmful tax practices. Now back to the case Belgium and its fiscal singularities, it is clear that its current corporate tax rate of 33.99%, one of the highest in the EU21, does not give an accurate representation of Belgium’s fiscal system. Indeed, fiscal rules such as the notional interest deduction and the excess profit scheme are worthy of a tax haven and if we can say that the excess profit scheme has been tackled by the European Comission, it is not the case for the notional interests. These kind of rules led to consider Belgium as a tax 17 Service Public Fédéral Finances (1992) Codes des impôts sur le revenu 1992, Version historique, Article 205/1,2,3 et 4 : Déduction pour revenus de brevets, Belgique. 18 http://www.entreprises.gouv.fr/files/files/directions_services/etudes-et-statistiques/etudes/autres/2013-11-etude-fiscalite-brevet-europe-nov12.pdf 19 http://www.taxworld.be/taxworld/deductions-pour-revenus-de-brevets-la-concurrence-saccroit.html?LangType=2060 20 https://www.oecd.org/ctp/countering-harmful-tax-practices-more-effectively-taking-into-account-transparency-and-substance-9789264218970-en.htm 21 http://ec.europa.eu/taxation_customs/resources/documents/taxation/gen_info/economic_analysis/tax_structures/2015/report.pdf

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haven, at least for foreign multinational companies, seeking to optimize their profits22. However, the situation is quite ambiguous because, for the employers, Belgium is everything but a tax haven and most of them are waiting for some reforms.

IV. Effects of the EU fiscal harmonization plans on Belgium

As we have shown in the previous part, Belgium has already been forced by the EU to abandon its excess profit scheme and most of the country’s other special fiscal laws face criticism by the EU or by other large institutions. Due to this increasing pressure on Belgium to change its fiscal laws, the country will have to react quickly before any severe sanctions are imposed on it by the EU or other harmed countries forcing it to remove its fiscal particularities. Today, Belgium has one of the highest corporate tax rates amongst EU Member States23; it amounts to 33.99% which puts it far above the average corporate income tax of the EU which is 22.37%. Belgium is thus theoretically very fiscally uncompetitive; this would cause Belgium to be highly unattractive for companies wanting to establish themselves in the EU. Today however, due to the many fiscal particularities of Belgium, the corporate effective tax rate of the country is of 4.8% which is one of the lowest in the EU and is thus very attractive for companies. This clearly exposes the vulnerability of Belgium towards fiscal harmonization in the EU: if it was forced to abandon its fiscal advantages by the EU, the country would go from one of the most fiscally competitive countries of the EU to one of the least competitive ones which would clearly harm Belgium. Belgium is thus in a great need of changes to its corporate tax system in order to be able to remain competitive in the case of increased fiscal harmonization. The Belgian minister of finances Johan Van Overtveldt has therefore offered to overhaul the system completely24 by diminishing the corporate tax rate to 20 or 22%25 which would place Belgium under the European average making it relatively competitive, attached to this 22 http://www.lalibre.be/economie/actualite/oui-la-belgique-est-un-paradis-fiscal-51b8f985e4b0de6db9c9be48 23 “Corporate Income Tax Rates around the World, 2015.” Tax Foundation. 24 “Plan D’action Pour Lutter Contre La Fraude Fiscale | Johan Van Overtveldt.” 25 “Réforme Proposée de L’impôt Des Sociétés: Réactions Du cdH, Des Patrons et de La FGTB.” RTBF Info, January 30, 2016

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decrease of corporate tax rate would be the elimination of the fiscal particularities detailed previously. This would greatly simplify Belgian fiscal laws and bring them to standards expected by the EU; furthermore, this would greatly benefit the Belgian SME’s due to the fact that the multinationals are the ones that benefit the most from the current fiscal conditions in Belgium. The reduction of the corporate tax rate would most likely have no significant cost for the State due to the fact that it would be able to collect more taxes from companies since they would no longer be able to decrease their taxable income base, this would compensate the losses of diminishing the corporate income tax. This proposal would be the first step in making Belgium more competitive fiscally while complying to the expectations of the EU, the State (with the help of the EU) should furthermore crack down on fiscal fraud which amounts to between €10 and 30 billion each year or between 2 and 6% of its GDP26. Belgium could use this extra revenue to pay the eventual costs of reducing the corporate income tax.

V. Conclusion We have thus seen that one of the EU’s top priorities is to create a fiscally harmonized union in order to address fiscal fraud. In order to do so, the EU has endorsed several action plans such as the BEPS Action Plan and the CCCTB, which are not compatible with some of the current fiscal particularities of some Member States, and most notably of Belgium. If laws such as the CCCTB were to be adopted, Belgium would become very vulnerable since it relies heavily on its fiscal particularities to attract companies. A more fiscally harmonized EU does thus indeed represent a challenge for Belgium. Therefore, Belgium’s finance minister has already proposed several changes to the countries’ fiscal laws which would make them more compliant with the expectations of the EU and which would allow the country to remain competitive if it was forced to abandon its fiscal particularities. The economic prospects of Belgium thus depend on the possibility that the new fiscal reforms proposed by the EU will be adopted and on the decisions the Belgian government will make regarding fiscal reforms in Belgium.

26 “http://www.rtl.be/videobelrtl/video/439335.aspx.” Bel RTL. Accessed May 15, 2016. http://www.rtl.be/videobelrtl/video/439335.aspx.

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Appendices:

Source: “Effective EU Corporate Tax Rates - Blogs - IIEA - The Institute of International and European Affairs.”

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Source: martinaweitsch. “Tax Is Complicated.” Rationaldebate, June 17, 2013.

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