LDS Tax reflects on the new government agreement and its tax implications on M&A
🚨 What is not included: maintenance of VVPRbis / liquidation reserve, ‘investment company’ tax regime and Pricaf / Privak Privée
➡️ Capital gains tax up to 10
👉 Progressive system for holdings of 20% or more
👉 Exemption for historically accumulated capital gains: importance of the defence/valuation file.
👉 What impact on the exit of family businesses?
➡️ RDT (Deduction of definitively taxed income)
👉 Shareholding condition (if less than 10%) raised from €2.5m to €4m and ‘fixed financial assets’ condition (for large companies)
👉 Limited impact on private equity thanks to retention of the ‘investment company’ regime
➡️ Carried Interest: competitive regime with a maximum of 30%. Less radical than the Van Peteghem plan? Structure via ManCo’s still possible (combination of investment company and VVPRbis / liquidation reserve)?
➡️ More flexible group contribution: what impact on acquisition costs?
➡️ Various measures with a positive impact for portfolio companies (accelerated amortisation, IT remuneration via copyright, lower labour costs, etc.)
➡️ Specific measures for real estate 🏠 Pressure on ‘share deals’?
💡👇 Read our discussion paper on the impact of the government’s agreement on M&A
✉️ Want to know more? Contact Olivier Gios, Dieter Dilliën or Katrien Willoqué