Who pays the tax bill in Belgium at assignment end?
When an assignee leaves Belgium, as well as memories of time spent in this outward-looking country, they will almost certainly leave tax bills in their wake. A specialist reports on the tax treatment of Belgian income taxes paid on behalf of expatriates after the end of their assignment in Belgium. An employee in the United States is assigned by his US employer to a group company in Belgium. He or she benefits from the Belgian special taxation regime for foreign executives (under the Belgian tax circular of 8 August 1983) during his assignment. The assignee works and resides in Belgium between May 2001 and April 2003 while remaining on a US payroll and being remunerated on a net basis. In 2004, the assignee’s Belgian 2002 income tax assessment has to be paid. As they are remunerated on a net basis, the company pays the Belgian tax bill. The question we need to answer is, ‘Does the tax paid by the company after the expatriate left Belgium represent a taxable benefit for the executive in
