The present note has not for purpose to give an answer to all the questions raised by foreign EEC interim companies who put people during short, middle or long term periods at the disposal of Belgian companies in the context of "services agreements". Generally these people are IT specialists and enjoy the benefits of the 1.408/71 EEC ruling meaning they stay under the umbrella of the social security of the foreign employer.


As regards secondments of expatriates to Belgium we frequently find the situation where the executive continue to be paid by the foreign company which seconds him near the Belgian company (within the framework of a provision of personnel) and curiously when on the basis of a net take home pay basis where taxes are paid by the Belgian company.  

In this context I raise three questions:

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The disastrous tax consequences, since income year 2014, of the Regionalization on some tax benefits (lost) as soon as an executive benefitting from the special tax status earns less than 25% of his earned income (those including his wife) from the exercise of an activity in Belgium has as result that some people seek to know the impact of a reduction in their days of professional travels to determine the most advantageous situation.

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