The Special Tax Inspectorate (BBI) targets the Belgian companies of the Dutch employment group Randstad. According to the BBI, an artificial construction has been set up to transfer profits made by Randstad companies in our country to Switzerland, writes ‘De Tijd’.
Thanks to a very favorable deal with the Swiss tax authorities, Randstad hardly pays tax on the money that flows into Switzerland from our country. The BBI has already fired tax claims totaling 72.68 million euros at various Randstad companies in our country that are involved in the construction.
The Belgian Randstad companies have taken out loans from the Swiss branch of Randstad and pay the interest thereon with income from our country. Thanks to a ruling with the Swiss tax authorities, Randstad only pays 1.87 percent tax on the interest that flows into Switzerland. In our country, the Randstad companies do not pay tax on those amounts, because they are already taxed in Switzerland.
Tax abuse
The BBI accuses Randstad of tax abuse. The Belgian companies would not need those loans from Switzerland and the construction would mainly have been set up so as not to have to pay withholding tax here.
The Dutch-speaking court of first instance in Brussels ruled in favor of the BBI earlier this year. Randstad will appeal against the verdicts and has also pushed for consultation between the Swiss and Belgian tax authorities.
The Belgian Randstad companies have already paid a large part of the more than 72 million euros in disputed tax assessments. If the group is ultimately proved right, it will receive the amounts (plus interest) back from the state.
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2023-08-23 02:46:00
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