19.01.2016, 21:59
Favourable Tax Decision in Belgium for Fortum's Financing Company
OREANDA-NEWS. The Belgian Court of Appeal in Antwerp has on 13 January 2016 decided in favour of Fortum's appeal regarding the 2008 taxation of Fortum EIF NV, Fortum's Belgian financing company. Based on legal analyses and supporting legal opinion, Fortum has made no provisions for the tax in the financial statements.
The Belgian tax authorities (BBI) can appeal the decision to the Hof van Cassatie (the Supreme Court).
The decision concerns Fortum's Belgian financing company, Fortum EIF NV, which granted internal financing to a Swedish group company for financing an acquisition in Russia. The Belgian tax authorities argued that Fortum EIF should not benefit from the notional interest deduction (NID) regime in Belgium. As Fortum EIF was established for genuine business reasons to manage financing risks, the Court approved Fortum's appeal.
The income tax paid in Belgium for 2008 was EUR 36 million. Fortum has also appealed the income assessments of Fortum EIF NV for years 2009, 2010 and 2011 in Belgium. Fortum's appeals concerning the years 2009-2011 are pending, and Fortum expects the remaining years to follow the decision from the Court of Appeal for 2008. In total, the taxes for cases for 2008-2011 amount to EUR 98 million. The additional taxes have already been paid by Fortum in 2012--2015, and they have been booked as receivables.
The Belgian tax authorities (BBI) can appeal the decision to the Hof van Cassatie (the Supreme Court).
The decision concerns Fortum's Belgian financing company, Fortum EIF NV, which granted internal financing to a Swedish group company for financing an acquisition in Russia. The Belgian tax authorities argued that Fortum EIF should not benefit from the notional interest deduction (NID) regime in Belgium. As Fortum EIF was established for genuine business reasons to manage financing risks, the Court approved Fortum's appeal.
The income tax paid in Belgium for 2008 was EUR 36 million. Fortum has also appealed the income assessments of Fortum EIF NV for years 2009, 2010 and 2011 in Belgium. Fortum's appeals concerning the years 2009-2011 are pending, and Fortum expects the remaining years to follow the decision from the Court of Appeal for 2008. In total, the taxes for cases for 2008-2011 amount to EUR 98 million. The additional taxes have already been paid by Fortum in 2012--2015, and they have been booked as receivables.
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