Belgian CFC Rules: Shift from a Transactional (Model B) to an Entity Approach (Model A) as from 2023

In December 2023, the Belgian federal Parliament adopted new rules to tax the non-distributed profits of a controlled foreign company (CFC). The previously applied Model B approach was replaced by the stricter Model A regime. The new Belgian CFC rules already apply as from the 2024 tax assessment year, i.e. fiscal years ending on or after 31 December 2023.