Translation of "withholding tax ordinance " (English → French) :

Implementing Ordinance of 19 December 1966 to the Federal Act on Withholding Tax | Withholding Tax Ordinance [ WTO ]

Ordinance of 19 December 1966 on Withholding Tax | Withholding Tax Ordinance [ WTO ]

federal withholding tax | withholding tax

tax deduction at source | withholding tax | withholding of tax | source deduction | deduction at source

Federal Act of 13 October 1965 on Withholding Tax | Withholding Tax Act [ WTA ]

tax withheld at source | withholding tax

25% flat-rate withholding tax which exempts the balance of income from tax

tax at source | withholding tax | source tax | tax deducted at source

rate of withholding tax [ withholding rate ]

tax deduction at source | tax deduction | withholding tax

In addition to the specific areas covered by the two accompanying communications, this Communication also identifies other areas of direct taxation (withholding taxes, anti-avoidance measures, inheritance taxes, etc.) where the Commission considers there is a need for a co-ordinated approach.

A Co-ordination Centre is an undertaking belonging to a multinational group providing services to other members of the group. Under a 10-year license granted by the tax authorities, the taxable revenues of a Co-ordination Centre are determined according to the so-called "cost-plus" method. The cost plus method is normally aimed at avoiding double taxation and limiting tax avoidance. In the cost plus method, the taxable profit is calculated as a percentage of the aggregated operating costs. Although this method of taxation does not constitute State aid per se, its practical application may well give rise to State aid. With respect to the ...[+++]Belgian scheme, the Commission has concluded that the Belgian authorities apply the cost-plus method in a way that gives raise to State aid. Firstly, Belgium systematically uses a default mark-up rate of 8% without verifying whether this rate reflects the economic reality of the services provided by the Co-ordination Centres. Secondly, the way in which the expenditure of the Centre is calculated excludes significant operating cost items of the Centre. Thirdly, the Belgian Co-ordination Centres enjoyed additional tax advantages such as a withholding exemption on income distributions and a real-estate property tax exemption. The benefits reduce the amount of taxable profits and thus grants an advantage not justified under the EU State aid rules.