In recent years, Dutch multinationals such as Heineken, Philips and Unilever have taken their corporate financial centres out of Belgium. Het Financieele Dagblad reports, on its Internet site, that in total more than €20 billion of such companies’ capital (share and other capital excluding debt finance) has been transferred to other locations. The investigation by the Dutch publication indicates that this trend is due to low interest rates. They serve to considerably limit the fiscal advantages derived from the deduction of notional interest.
Notional interest was implemented in Belgium to replace the coordination centres regime, which came under fire from the European Union. The system enables a given company to deduct theoretical interest calculated on the basis of its share capital value. This theoretical rate is based upon the rate of ten-year Belgian state bonds, the values of which have highly diminished in recent years, within a context of a highly accommodating monetary policy combined with rates of interest that have hit rock bottom.
According to Het Financieel Dagblad, at the end of 2011, Dutch multinationals still had €26 billion of such capital funds in Belgium. However several companies have now withdrawn from Belgium, such as Heineken which decided in 2016 to bring its financing activities back to its head office in Amsterdam. Up to that point such activities had been located in Belgium. The chemical company DSM and the Philips group have done the same. Other multinationals, such as Randstad and Unilever, have looked elsewhere, specifically Switzerland, given that the grass is no longer green in Belgium. Only the company ASML still has a substantial portion of its capital value in Belgium.