DT3404 - Belgium: Dividends

Under the current agreement a United Kingdom resident recipient beneficially entitled to a dividend from a Belgian company will pay the following reduced rates of Belgian withholding tax:

• Under the EU Parent/Subsidiary Directive, 0% if the resident is a UK company holding at least 25% (but see below) of the capital of the company paying the dividend;
• Under the UK/Belgium treaty, 5% if the recipient is a United Kingdom resident company not within the above, but controlling directly or indirectly 25 per cent of the voting power of the Belgian company
• all other cases: 10 per cent.

The level of capital required to obtain the 0% rate is reduced to 20 per cent from 1 January 2005, 15% from 1 January 2007 and 10% from 1 January 2009.