Inbound investment: Belgian patent company
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Upon acquisition of a portfolio of patents that have not yet been commercially exploited in Belgium, transferring them to a Belgian company may be the way to go. Depending on the value and the return the portfolio generates, an effective tax rate of as low as 0% may be attained.
 
Main features
  • Patent income deduction (PID)
  • No capital duties upon contribution
  • Patents may be tax-depreciated over their useful economic life
  • Application of increased (spread) investment deduction (currently 14.50% / 21.50%)
  • Notional interest deduction of (currently) 3.781% on “fiscal net equity”
  • Application of EU Interest & Royalties Directive and extensive treaty network
  • Renewed Belgian ruling practice (pre-filing meeting possible on no-name basis)
  • No capital gains taxation at the end as the patents expire
  • Application of “tax sparing” clauses contained in certain double taxation treaties (e.g. Greece, India, Brazil, China, etc.)
  • Payroll incentives, e.g. expatriate tax regime and payroll withholding tax relief

Example

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