The Belgian Ministry of Finance has published Circular Ci.RH.421/630.788, which covers the scope and application of the Fairness Tax entered into law in July 2013. The tax is a separate corporate assessment of 5.15% (5% + 3% crisis surcharge) on distributed profits (dividends) that were not effectively taxed due to the application of the notional interest deduction or losses carried forward beginning assessment year 2014.
The Fairness Tax applies to large companies established in Belgium and …