From the Archive – August 2011 by Milton Grundy
Attentive listeners to Richard Pease’s presentation in Amsterdam in 1995 will have picked up the information nugget (if they did not have it already) that a Belgian company with a branch in a treaty country does not pay Belgian tax on its branch profits. One member who was in the audience at that meeting was able to advise a construction company which landed the job of extending a Russian airport (a job which would take less than 12 months) to use a Belgian company for the purpose. Like so many European companies, Belgian companies are so much easier to get income into than to get income out of. Where the ultimate owner is a zero-tax vehicle, it may – as Werner Heyvaert pointed out in Geneva in 2010 – hold the Belgian company through a Luxembourg company in liquidation.