Cross-border rental of equipment: a major tax obstacle has been removed
Cross-border rental of equipment: a major tax obstacle has been removed
When leasing or renting tangible assets on the international market, Belgian taxpayers today sometimes experience competitive disadvantages because in principle 30% withholding tax is due on the fees paid. Although many of the double taxation treaties concluded by Belgium provide for an exemption, this depends on the exact wording of each double taxation treaty and is also subject to a series of formalities.
This administrative process is often time-consuming, is a disadvantage in an internationally competitive market and can lead to delays and uncertainty for taxpayers.
Therefore, on 31 October 2025, a Royal Decree was issued introducing a domestic exemption of withholding tax for payments related to the rental, lease, use and concession of tangible movable property. The provision of intellectual property cannot benefit from this specific exemption.
A one-off attestation obligation is provided for whereby the debtor must complete this certificate so that it becomes possible for the administration to check the conditions of the exemption. This certificate must be renewed with every change. In this way, a debtor can make use of the exemption with a minimal administrative burden.
This exemption will take effect for awards or payments from 1 November 2025.
If you have any questions about this, please contact Hubert Hellraeth.
This administrative process is often time-consuming, is a disadvantage in an internationally competitive market and can lead to delays and uncertainty for taxpayers.
Therefore, on 31 October 2025, a Royal Decree was issued introducing a domestic exemption of withholding tax for payments related to the rental, lease, use and concession of tangible movable property. The provision of intellectual property cannot benefit from this specific exemption.
A one-off attestation obligation is provided for whereby the debtor must complete this certificate so that it becomes possible for the administration to check the conditions of the exemption. This certificate must be renewed with every change. In this way, a debtor can make use of the exemption with a minimal administrative burden.
This exemption will take effect for awards or payments from 1 November 2025.
If you have any questions about this, please contact Hubert Hellraeth.