Dividends paid to companies in non-EU tax treaty countries can benefit from the Belgian withholding tax exemption if that treaty (or any other treaty) provides for the exchange of information necessary under applicable rules. Previously, the tax treaty with Switzerland did not meet that condition.
Switzerland recently ratified the OECD/Council of Europe convention on mutual administrative assistance in tax matters. The convention provides for such an exchange of information, effective with its entry into force on 1 January 2017. Accordingly, dividends paid to a Swiss company can benefit from Belgium's withholding tax exemption as from 1 January 2017, provided that certain conditions are met.
Read an October 2016 report prepared by the KPMG member firm in Belgum: Dividends paid to Swiss companies can benefit from internal withholding tax exemption as from 1 January 2017
The KPMG logo and name are trademarks of KPMG International. KPMG International is a Swiss cooperative that serves as a coordinating entity for a network of independent member firms. KPMG International provides no audit or other client services. Such services are provided solely by member firms in their respective geographic areas. KPMG International and its member firms are legally distinct and separate entities. They are not and nothing contained herein shall be construed to place these entities in the relationship of parents, subsidiaries, agents, partners, or joint venturers. No member firm has any authority (actual, apparent, implied or otherwise) to obligate or bind KPMG International or any member firm in any manner whatsoever. The information contained in herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 4366, 1801 K Street NW, Washington, DC 20006.