Tax Law - Belgian Service Centers

1. INTRODUCTION

Multinational groups are increasingly seeking to concentrate customer services in regionwide Service Centers. In a recently published administrative circular (Circular Ci. RH.421/483.766 of July 26, 1996), the Belgian Tax Administration has responded to this trend by providing a procedure for granting advance pricing agreements to fix the tax base for such Service Centers for a five-year renewable period.

An authorized Service Center may take the form of either a resident Belgian company or the Belgian branch of a foreign company. The status may be requested on behalf of a newly-created entity or on behalf of a company or branch already in operation.

A distinguishing feature of the new circular is the broad and open-ended scope of intra-group activities which it includes. The new circular can be applied to a Call Center, set up to provide easy access by telephone for group customers seeking information on available products and services or looking for a