Proposition 54K2864

Projet de loi portant réforme de l'impôt des sociétés.

General information ¶

Authors

CD&V Servais Verherstraeten
MR David Clarinval
N-VA Peter De Roover
Open Vld Patrick Dewael

Submission date

Dec. 20, 2017

Official page

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Status

Adopted

Requirement

Simple

Subjects

tax law tax system reflation corporation tax

Voting ¶

Voted to adopt

CD&V Open Vld N-VA LDD MR

Voted to reject

Vooruit PS | SP DéFI PVDA | PTB

Abstained from voting

Groen Ecolo LE ∉ PP VB

Party dissidents ¶

• Olivier Maingain (MR) voted to reject.

Contact form ¶

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Discussion ¶

Dec. 22, 2017 | Plenary session (Chamber of representatives)

Full source

The rapporteurs are Mr Crusnière and Van de Velde.

I am very pleased, colleague Van de Velde.

Mr. Speaker, I am pleased to refer to the written report, but I would like to add that it was due to an unlikely effort of the services of the House that this report, also in writing, is available today. I would like to express my thanks to the services for this. (The applause)

Thank you, Mr Van de Felde. As I said, the general discussion has been opened.

Currently, only two speakers are registered, but I imagine that other members will not fail to register.

Mr. Speaker, dear colleagues, we are at the end of the start of our marathon, which will continue throughout the next year to discuss the corporate tax reform.

That said, it is difficult not to mention the political context in which things are happening, namely a summer agreement that was celebrated in Tomorowland, but which, in the end, will be without future since half of the projects that are the subject of the said agreement are postponed while we were told that the said projects formed a politically coherent whole and that it was necessary to discuss and vote on them in their entirety.

However, we are far from counting since this completely absurd and unbearable project, which provides for an exemption of 500 euros for the so-called occasional work, is postponed to next year. Some members of the majority have, in addition, not failed to let me know that they were satisfied with it, proof of this is that this project is carried out only by one party, namely the Open Vld, who is thus disguised. There is no fault in warning them. Indeed, we told them that their project was not on track, that it had been elaborated without social concertation, without concertation of the other levels of power, that it was banal from a legal point of view and that time had to be taken to consider it serenely.

More surprisingly, another case is postponed to next year, namely the one concerning the tax on securities accounts. So here it is very strange, because this file does not seem to be intrinsically related to the other project relating to the exemption of 500 euros per month. But it was deliberately and politically bound by the majority for reasons that are obviously explained by a problem of cohesion within the government majority, so that this dossier, which was perfectly in the state of being voted, is also returned sine die. In my opinion, this is more than likely the beginning of a long saga.

All this, of course, in terms of politics, does not give your government and your majority a flattering image! You claim to bring solutions when you are unable to solve your own problems. This is the first finding that is the introduction and the general framework in which we will have our discussion of the corporate tax reform.

So today you have a majority that is disunited, which produces political crafting, legal crafting and, in the end, legal insecurity. Because this climate you create yourself is not conducive to developing a policy that can claim economic efficiency and legal stability.

In concrete terms, this means that the expectations of the population, in terms of their living standards, their well-being, their social protection; the expectations of the economic world, which wants measures favourable to employment and investment in a safe environment, today, reflect their concerns.

They tell us that they are mobilizing by tens of thousands in terms of pensions. They let us know it through communications, requests for hearings that are, unfortunately, organized in the rush! It was necessary to convince you – but at the forceps – to hear all the social partners, but also the volunteer sector, the Union of the middle classes, UNIZO, the FGTB, the CSC, CGSLB, the FEB, as part of your bill on the 500 euros, on occasional work and it is really only at the last minute that you consented to carry out these hearings.

Similarly, on corporate tax, the Union of the Middle Class, from the month of October, addressed you this message: you are making a corporate tax reform by cheating the eye, we want to be heard. This is also the end of not receiving. It would have taken courage, but also the determination of the opposition, especially of the Socialist group, to demand and obtain these hearings in a ⁇ difficult context. In short, you are not implementing all that should be done to develop a policy worthy of that name, which pursues both general interests but which also aims at effectiveness. We are far from counting.

Therefore, the instability of your government also produces instability in general, and in particular, as regards the economic and social fabric. The government was improvised, improvised. Moreover, strangely, it would take you six months, between July and today, to file these laws. What did you do for six months? It took you all this time to be able to transpose, formalize into bills, agreements for which you had swept the champagne at the Tomorrowland festival, with moult photos, as well as to better narge those and those who do not expect you to go to this festival but rather you take care of their situation trying to find solutions. We are really far from counting.

Then, we have to tell you how much you have, in your methodology, missed everything there was to succeed. You first had to make sure, for a text as fundamental as the proposed corporate tax reform, its legal reliability. You should be able to carry out a work that, from the point of view of law, is rigorous, that is, that leaves no room for approximation, that seeks to remove the spaces of contestation, that allows to avoid that you find yourself tomorrow with problems both with the European Commission, which could blame you for non-compliance with European law, and with a whole series of actors who, considering that they are discriminated, could dispute your texts before the Constitutional Court.

And for that, one thing was to do: consult the legislation section of the State Council. Of course, you did, but by asking him, for such a large file of over 700 pages, to answer within thirty days.

The State Council explicitly accuses you of this. The State Council tells you that it has not been able, in thirty days, to provide a serious and sufficient analysis of such a vast and complex text, understood that there are certain points on which it will not take a decision, due to lack of time! And, even though he pronounces himself, he discovers that there are problems in different places.

So you took six months to formalize your corporate tax reform project, but you left only thirty to the State Council to give you an opinion that might have avoided some problems.

The second false step, your relationships with the economic and social tissue. You tell us that you have consulted and associated a number of actors – in fact, FEB, UNIZO. Then, we also learn that the UCM as well as Brussels and French-speaking SMEs have not received sufficient attention from you.

Mr. President, you have stated the opposite in the committee. But yesterday, we heard the Chairman of the UCM say and recall that, of course, there had been informal exchanges between advisors but no real discussion with the official representatives of the UCM under conditions allowing the contradictory debate, allowing to be heard on certain points, clarify figures, simulations and clarify issues of opportunity.

It is not all about numbers. To match your announcement of a 14% drop in the ISOC while they find that there are sometimes only a few hundred euros earned, when in some cases they do not lose there, that is the real problem! It is discovered by doing this that, not only has the UCM not been heard as it should, but, in addition, it gathers insults, insults I say well, from a certain number of members of the majority; this is totally unacceptable!

Do I understand the discussion as follows?

According to the Union des Classes Moyennes, a company that pays at least EUR 45 000 to the executive can benefit from the reduced rate. Her argument is then that in Brussels and Wallonia the amounts will be lower, since they pay less. The logical consequence of this would be to bring that figure down: not more than 45 000, but from 30 000, or 20 000, or 15 000. Therefore, it is necessary to recognize the color in the discussion. There is a lot of time spent on the argumentation of the Union des Classes Moyennes.

Is the PS in favour of using 40 000 or 35 000 instead of 45 000, in any case a lower amount than currently proposed?

I would like to get an answer.

Mr. Laaouej, what is not insignificant is that the 50 % rule is very clearly contained in the whole framework of the bill.

I would like to ask you, in response to the question, if you would like a reduction. If you want a reduction, then what would you do with that 50/50 ratio between profit and salary executive, which allows the general principle as an exception?

The economic situation for a self-employed and a small enterprise is not the same every year, and I can imagine that business managers receive a different salary in one year than the other. I think that is nothing more than logical.

So why do you think a reduction is good and why do you not mention that 50/50 ratio?

This question is a little strange.

Who talked about reducing the amount of 36,000 euros? I read the report in extenso last night, which took me a few hours. I challenge you to find in this report, from the exchanges we had in the committee, a single phrase indicating that any member of the opposition would have said that this amount should be reduced by 36,000 euros. I’m talking about the remuneration of business executives, for those who follow our debates and who wonder what the subject is.

I respond to Mr. Bogart. He wasn’t there, but I don’t use such arguments. Mr. Van Rompuy may be able to pass on his file. No one has requested to reduce the current amount to 36 000 euros.

For the rest, the 50/50 rule already exists. If you actually allocate a remuneration at least equivalent to the taxable result of the year, you are entitled to the reduced rate. No one says the opposite and no one wants to question this.

Mr. Bogart, if you haven’t read it, I’ll teach you it. It is strange that you have removed a provision, the famous 13% rule. Do you know her, Mr. Van Biesen? Who knows her? Mr. Van de Velde knows her, Mr. Piedboeuf also, like everyone else. I will repeat it anyway.

In order to be entitled to the reduced rate, it is not necessary to distribute more than 13% of dividends in relation to the capital. What is the reason for this measure? It’s about avoiding undercapitalization of companies and encouraging companies to keep money within them to enhance their solvency and their prospects for sustainable growth.

The Chairman of the Union of the Middle Class said: “Our figures and our simulations do not show that you are fulfilling your commitment to lower corporate tax for SMEs by 14%. This may be true for large companies, but not for SMEs. On the other hand, we looked at the sociology of our Brussels and Walloon companies. We find that a majority of people don’t give 45,000 euros. We are much lower. We are actually closer to the 36,000 euros, neither more nor less. We say nothing else.

Mr. Van de Velde and Mr. Bogaert, just before 10:00 am, I received an email – I think other opposition groups have received it – reporting on an email exchange between the Union of the Middle Class and the cabinet of Mr. the Minister of Finance, with considerations on the figures. That is the problem! This is a problem of methodology. You did not give the possibility of a contradictory debate with the Union of the Middle Class.

Mr. Piedboeuf, I regret that someone like you is not sensitive to what representatives of the Union of the Middle Class, i.e. Brussels and Walloon SMEs, say to you: “We can exchange arguments, you can tell us that we are right or that we are wrong. But give us the opportunity to be heard!"It is obviously too late! You have abandoned the middle classes, Mr. Piedboeuf. This is the reality!

Mr. Speaker, I would like to thank Mr. Laaouej for his very clear answer. He says he does not want the PS to drop that threshold of 36 000 at all. This is exactly what the Union of Middle Classes demands. That is the point of the whole political debate.

Mr. Laaouej, there can be discussion about how the interaction went, but the point of the whole political discussion is that the Union des Classes Moyennes says that that 36 000 is too high for the French-speaking companies in Wallonia, because the profits are lower there. You respond by saying that you do not want to change that threshold at all.

What is your political point? You complain that the Union des Classes Moyennes is not heard and not followed, but at the same time you declare yourself that you do not want to lower the threshold.

Of course, I totally disagree with what Mr. Laauouej has said. Furthermore, separately, after the hearing of the UCM, the head of cabinet of Mr. the minister reminded him of the dates of communication of all the information to which the UCM did not respond or did not follow up. I’m sorry to say that the UCM has been consulted; it has even been consulted several times, as well as UNIZO. The chairman of the UCM even acknowledged the fact that what the affiliated companies were asking was well heard, i.e. a reduction from 90,000 to 70,000 euros. Mr. the Minister of Finance will be able to give you the dates of the communications that occurred between his office and the UCM. so to say that there was no contact with the UCM is a lie!

Mr. Laaouej, I cannot accept that you are claiming that we have given up SMEs with the present reform. This goes against reality.

You take one measure out of it and you continue to hammer on the measures regarding the ceiling when rewarding the business manager. However, this is one of the measures in the corporate tax reform package. However, I do not hear you speak, although you know it, about a number of other measures included in the reform, all of which aim to make the reform just fair for SMEs in relation to the big companies. This justice has always been addressed and is one of the objectives of the reform.

First, there will be a large general tariff reduction for SMEs, which is also a goal of this reform. SMEs have also always called for lower rates and to make corporate taxation less complex, including by introducing fewer deductions and exemptions. That is the deal that is in the corporate tax reform.

Secondly, it is also agreed for SMEs to work towards increased investment drainage, which is also of great importance for SMEs, in order to provide the necessary space to invest.

There are also additional incentives for research and development. You also know that in this area, in the forthcoming corporate tax reform, huge efforts are being made to provide more oxygen for investment, research and development.

The next point is also important. You argue that we have given up the SMEs. I assume that you also find independent natural persons important in doing business. The reform includes a whole package of measures to help self-employed natural persons, to eliminate the difference between working under corporate tax and working under self-employed natural persons, and to give those self-employed natural persons more oxygen.

All these elements are forgotten, ⁇ consciously, in your argument. However, there are elements that all make this reform truly SME-friendly.

Can we receive a copy of your exchanges?

Mr. Minister, could we receive your email exchanges with the Union of the Middle Class? I’m talking about the content, not the schedule. Is it possible to copy them so that members can get acquainted with them?

I will respond after the Minister’s response.

Mr Laaouej, I thought I understood that Mr Vanden Burre wanted to speak.

I would like to comment because this debate still occupied a large part of yesterday’s afternoon. I am speaking not only of the UCM hearing, which we had claimed with cor and cry and eventually obtained, but also of its possible inclusion in the discussion. The colleague Piedboeuf – you confirm it, Mr. Minister – claims that the UCM has been integrated into it. Honestly so much better! But then why, during yesterday’s meeting, the president of the UCM stated the opposite? I don’t think it’s in his interest to come to an audition – as he has been asking for a long time, like us – to make inconsistent statements, or even to tell lies.

Mr. Pietro, you accused him yesterday of lying in the commission. He actually said, text, that he had not been consulted. Mr. Laaouej refers to a message that we received this morning from the UCM. I read it: "We would have wished to be contacted in advance of all this debate that is taking place in the urgency and precipitation."

It must be correct and consistent. What really happened? What kinds of meetings were held or not? Indeed, one of the main remarks of yesterday and completely unacceptable misunderstandings is that the UCM was not involved in the discussions and debates, that they could not have their point of view. Everyone discovered yesterday afternoon in the committee, during the debate on the numbers, who is right, in which case, etc.

Sorry, but we’re going to take everything in the reverse. And you tell us today that there is no problem, that we have seen each other since February. Who are we laughing at? I would like to understand something here, it is incomprehensible.

Mr. Minister, I would like to ask you a question. You are talking about electronic exchanges. It happens every day, even regularly between groups of the opposition, of the majority. This does not mean that we are negotiating, that we are negotiating. This means that we exchange. I have a simple question to ask you. As you know, the UCM is one of the social partners. Did you personally receive the Union of the Middle Class in the file of the corporate tax reform?

very well . We have our answer. There was no consultation or discussion with the representatives of the UCM! If you want emails that can be exchanged between collaborators, I’m on the go! This does not mean that there is a negotiation or negotiation. This is not a concert! When there is consultation, decision-makers meet. Among the decision-makers are the members of the government and the representatives of the management bodies, not the employees!

I have another question to ask you. You presented the corporate tax reform to the FEB. Could you remind us when it was, Mr. Minister?

When did you go to the premises of the FEB to present the corporate tax reform? When did this meeting take place?

It should be remembered that this was before the bill was submitted to parliament. Can we know when you plan to submit your corporate tax reform to the Middle Class Union?

I do not disagree.

Are other members still asking for the word?

Mr. Laaouej, the debate we had yesterday was already thumbing, but I must say that today, unfortunately, is not much better.

First, in all these types of relationships, it takes two to tango. When a cabinet, ⁇ in this kind of important reform, makes its data available and sets itself vulnerable and calls for response, pointing to certain trends and developments, then I dare to assume that the great interest organization you refer to does its job properly. I don’t think it’s about looking at how the cabinet and the UCM have reacted. I have 100% confidence in the way the Cabinet has made its data available.

But the essence is what comes out of it. What is the material criticism, and does that criticism continue today? I already pointed out yesterday that we want to go to that rational debate. We will be very pleased to compare the figures. You know, like me, that somewhere we will find a company that progresses a little less on it. We will find them, believe me, but the essence is, of course, that one has formed a total economic profile to which 99% of the enterprises will go, and to which the entire economic tissue will go. That is the essence of what we do today.

I get, both yesterday and today, a very uncomfortable feeling because we focus very strongly on some kind of interference or defense, based on a single statement of one figure. He may say that he has the entire organization behind him, but if I see what the efforts are in the proposal for the benefit of all self-employed and small entrepreneurs, then I find that the substantial comments made yesterday are just à côté de la plaque. They are simply not right. So the essence of the story is not who said what, but whether or not it is true. Well, I tell you that it is not true.

Dear colleagues, first of all, I have heard the Minister of Finance in the committee say that the corporate tax rate should be reduced, because multinational companies want to invest in our country and wait for a sign. It is clear that this sign – the decrease in the corporate tax rate – was aimed at multinationals.

Then I was going to say the same thing as Mr. Laauouej. He was faster than me. I did not mention that Mr. Minister of Finance was invited for a lunch-discussion at the UCM, but he participated in a lunch-discussion at the FEB. The FEB was heard. The initial proposal for corporate tax reform did not provide for 100% RDT (definitely taxed income). The FEB said: "We want the RDT to go from 95 to 100%." It has increased RDTs from 95 to 100 percent. The FEB was therefore perfectly heard.

The share surplus also increases to 100% as the existing tax is removed. On the other hand, RDT conditions are introduced in order to be able to deduct surplus values on shares. Who will be affected? Who, in many cases, will no longer be able to deduct its surplus values on shares, failing to meet the RDT conditions? The SMEs !

It is clear that this project is tailor-made for large companies. In selling the goods, it was said that SMEs would benefit from it. I will demonstrate recently in my presentation that SMEs are not the winners of this reform. This reform has been tailor-made for large companies. The FEB thanks you, Mr. Minister!

Ms Smaers, you mentioned the deduction for investment. When will it end? This is a question I ask you. You said there are good things. The deduction for investment is a very good measure. It already existed. It has been increased. But until when, Madame Smaers? When does the largest deduction for investment start and when does it end?

Something does not happen immediately. Some measures will not enter into force until 2020 and will have effect.

No, that is not my question. When will it end?

The [...]

Here, Mr. Van Biesen responds in your place. You are talking about increasing the deduction for investments, except that it ends in 2020.

Bravo to! I thank you, Mrs Smaers.

What is the rate of the penalty for insufficient remuneration?

This is not a quiz, Mr. Laaouej!

This is a quiz. This is exactly a quiz, Mr. Bogaert!

You question me, you ask me specific questions, to which I answer you. Are you able to answer me? You are unable to answer me! What does this mean? That once again, Mr. Bogaert – it is you that I target in particular – you do not participate in the work, you come once in a while and you distribute good points by telling anything.

Even Mr. Van Biesen and Van de Velde did not tell me that we had requested the reduction of the €36,000 No one ever asked for it. And, as far as you are concerned, you come with ideas and questions, which is why I allow myself to bother you a little.

If you want to give lessons, Mr. Bogaert, you must be able to do it. This is not given to everyone. However, this is not the first time you do this. I still want to tell you!

Mr. Pieboeuf, you say the UCM lies.

No, it is you!

No, I report what the UCM says. Indeed, we were many to hear the statement of the president of the UCM that the latter had not been concerted.

You say the UCM is lying. Bravo to! Not only do you not consult her, but you also treat her as a liar. With you, it is the double penalty. You exclude middle classes from the reduced rate and you impose an additional tax penalty on them. Not only do you not consult them, but you also treat them as a liar. In other words, with you, it is always a double punishment.

Mr Laaouej, if you allow me to speak, I will give the floor to Mr Bogaert.

I have not finished answering everyone.

In this case, I invite you to continue your speech.

Mr. Minister, in my opinion, when we make a corporate tax reform that weighs 5 billion euros, which will impact several hundred thousand companies, when we know how much this matter is ⁇ sensitive for SMEs, we take the time to call people to let them know that we want to work and consider, with them, how to do so.

It is not the big law firms or the tax experts of your office or your administration, for whom I have respect, who will tell you what is appropriate or not from an economic point of view, it is the economic and social actors. In my opinion, you should have even consulted the staff representative organizations. Indeed, if companies provide capital, this is also the case for workers, who also have the right to know within what legal, social and fiscal framework their company will develop.

As a Minister of Finance, you should have worked with everyone.

For the rest, you prepare for us the inventory of electronic exchanges. I asked the Union of the Middle Class to check this morning. Two of their emails, once the decision on the project was formally made, remained unanswered, while they contained a request for last chance hearing. I ask you to check with your services, but we will also produce UCM exchanges with the members of your cabinet. These show that there has been no consultation and discussion on their last request, which concerns only two or three measures, but these are very important for them.

We cannot, on one side of the hand, sweep them under the pretext that it is only a few thousand euros. I will go back to it if you allow me to develop my words. For a very small company, a few thousand euros count. SMEs are not multinational companies. These are people who have trouble getting out of it, who are dependent on order books that don’t follow, late suppliers, a bank that refuses them a cash credit and a sometimes difficult environment. We also need to consider small subcontractors.

For the rest, I had committed myself to you, Mr. Van de Velde: we will not begin to examine things at the tribune, column by column. It would be surreal. I asked for a simple thing. What you did during the contradictory debate is respectable. The UCM has provided figures. You brought others. This is what makes the reason for our Parliament and our democratic debate: the contradictory aspect. This is true in a parliamentary institution, and in others, such as the judicial institution. The conflicting debate must be able to take place in good conditions, not between two doors. Not during a late meeting, after a plenary session, during which we do not have time to deepen the subject. Contradictory debates require time. Certainly not many weeks, but time.

We did not have this contradictory debate. You will tell me it could have happened next week. For various and varied reasons, on which I will not return, it has been considered necessary, in order to avoid any difficulty, to shorten things a little. We could have voted next week. From the moment we asked for the hearing, in this interval – remember, Mr. Van de Velde: I asked for it in the first reading. You are a witness to this – the majority opposed a niet. No, listening to the middle class is not necessary! We only got it yesterday or before yesterday. What does this mean? That you did not understand how important it was to organize the contradictory debate with the Union of the Middle Class! It could also happen with UNIZO and even with FEB. I can have a contradictory debate with the FEB. But you refused that. This is a methodological problem that we blame you.

I will not go into the arguments ad hominem. They are usually a sign of weakness. I remember that here in a previous discussion suddenly came the argument that someone was wearing a costume and a dress. That was then the most important contribution. I’m sure you’re wearing a robes and costumes today, but let’s talk about politics.

Is this not true, Mr. Gilkinet?

I challenge you, Mr. Laaouej...

Colleagues, we might just be able to limit the debate to what it is about, in particular the corporate tax.

and exact . That is my point, Mr. Speaker. Let us discuss politics. I challenge the PS.

You started well!

We will discuss politics.

I know you had a congress. You may find it yourself a little too left-wing and too revolutionary and that is why you want to draw the map of SMEs and SMEs here today. I challenge you. Please submit an amendment. Follow the UCM, which you have been so passionately defending for half an hour. Submit an amendment to reduce the €36 000 that we are discussing to, for example, €24 000. You do not dare!

I do not think it is that amendment that you will submit. The proof of the pudding is in the eating. If you want from 36 000 to 24 000, please submit the amendment. We will see who is on which side of politics.

Mr. Speaker, I would like to respond to my colleague, Ahmed Laaouej.

I didn’t say the UCM was lying. I said that to say that the UCM had not been concerted—these are your words—is a lie. Indeed, at the end of the hearing, when the head of cabinet of Mr. Minister went to Mr. Nyst to tell him what were the dates of communication of the information, he said out of the microphone: "I can't deny this." He acknowledged that he had actually been contacted.

And I add that, on November 15, 2017, a little more than a month ago, I attended a one-day seminar organized by the Belgian Fiscal Letter, which you know. This seminar was co-organized by the UCM and aimed to present the entire project of corporate tax reform. There was therefore a perfect knowledge of this reform, already at least two months before. There were exchanges but no reactions. It is still weird!

Like most of us, I received reactions from the UCM, here a dozen days ago. On the one hand, I do not understand that we have not received it before. On the other hand, in a committee, the Chairman of the UCM thanked us for taking into account the comment on related companies. If she thanks the politicians for taking something into account, it means that the UCM had been heard on this point. It may not have been in everything. I said it myself. It is true that we do not like all measures, but they are part of a global balance. It is clear!

The three remarks of the UCM, which was also present on 15 November 2017 at the presentation of the Fiscal Letter, are part of a coherent set that takes into account the financial and budgetary reality of our country. You can’t shake your fingers and say that you have to do this or that. No, we must first respect our international commitments, take into account the state of our budget and make a major reform. And, in fact, lowering the rate to 20 percent is a major reform. This is a first step. The others will be done later.

I regret to have to tell you that there was a concertation that, unfortunately, was one-way. The reactions occurred just a few days ago.

Colleague Laaouej, you are trying to provoke our statements on the timing of the entry into force of a number of measures. What was said then is true, a number of measures are intended to be introduced gradually. It is, of course, also a medium and long-term corporate tax reform. We cannot do everything in a year.

I find it quite a punishment, on the one hand, that you want to blame us that we do not go fast enough with the reduction of the tax and the increase of the investment deduction, while on the other hand you criticize and say that the corporate tax reform should be budget-neutral. It is of course one of two things. Budget neutrality is also important for us. I think this is less the case for the PS. For us, budget neutrality is of great importance for the well-being of citizens and ⁇ . This was also one of the starting points of the corporate tax reform.

Mr. Speaker, I would like to say to Mr. Piedboeuf that one can obviously make distraction by mentioning email exchanges, seminars, discussions, etc.

There is one question that I clearly asked yesterday to the UCM president during his hearing: Have you been received by the Finance Cabinet? He answered “No.” How can one imagine a concertation worthy of this name without having a capacity for listening, for dialogue and therefore for encounter? There was no meeting. There was no concertation.

Another element, Mr. Piedboeuf, you say that the UCM is satisfied with the decision that was taken in the end by the government regarding the related companies. Yes, but why was this decision made? Because it was a claim from UNIZO. The difference between the government’s attitude towards this request and the UCM’s claim regarding the minimum income of the leaders is that, in one case, it benefits UNIZO, in the other case, it is a demand of the Walloon companies. And that is the problem! It is that in the decisions of the government, you have not taken into account the specificity of Walloon SMEs.

To conclude, Mr. Speaker, I truly regret that the so-called “Reformer” Movement could conduct such an important reform in this way, turning the back to objective allies and beneficiaries of this reform who effectively demanded that their own characteristics be taken into account. Instead, you swept them from a reverse of your hand!

Mr. Speaker, the problem of this government – it appeared very clearly yesterday – is that its conception of social consultation, it is a little “cause always, you interest me!” It is the minimum service before the time, in terms of consultation, and the conduct of the majority, including Mr. Piedboeuf in relation to the UCM was yesterday unacceptable!

So yes, Mrs. Smaers, the ambition of this tax reform, which we have called out of our wishes to facilitate entrepreneurship in our country, must be budget neutrality. You are far away! I will come back soon, and other colleagues too, I suppose.

But as far as SMEs as such are concerned, it is not up to them to pay the tax reductions to benefit SMEs. This is what is happening in your reform. Especially since it is not any SMEs you call to pay: it is those who start, those who are in difficulty, those who are not able to grant their executives a salary level beyond the €45,000.

If you wanted this budget neutrality, some measures should be avoided. You increase the deductibility of permanently taxed income from 95 to 100%. Cite me a SME that will benefit from this measure that will cost tens of millions of euros! The European Commission has adopted the European Directive against Tax Evasion. A small and medium-sized company practicing tax evasion. You have, in this text, taken new measures for the benefit of actors who do not need them – because making profits already very large and which will turn them into dividends rather than jobs – and you penalize the smaller actors. But what a missed opportunity, in your boss, and I will come back soon!

I propose that the interruptions be limited to only one to return to the speaker at the tribune. Furthermore, as agreed in other debates, interruptions are limited to two minutes and no more.

Mr. Bogaert had interpelled me saying that if we support SMEs, we would only have to submit an amendment. We submitted it to the committee, but it was rejected by the majority. Our amendment was aimed at meeting the claim on the minimum wage. (Brouhaha) by

Mr. Bogaert, you told me to submit an amendment if we support SMEs. We have submitted an amendment to the Finance Committee on the remuneration of managers. You were not there. I can understand that you did not know it, but I will inform you.

It was rejected by the majority and by your party as well. I will present it again today in the plenary session.

Mr. Piedboeuf, without epilogging, the concertation is to receive people, to open a discussion, to open a calendar. The consultation is not limited to electronic exchanges between employees. It was Mr. the Minister who was supposed to sit at the table with them from the moment when, as early as October, they considered that this was an eye-tricking reform for SMEs. I am sorry, Mr. Piedboeuf, the MR has abandoned Brussels and Walloon SMEs.

Mevrouw Smaers, yes, there are compensatory measures, and that is the problem. I affirm in the analysis that this reform is not SMEs-oriented: yes, there is a reduction in the rate, but in exchange for what? Additionally, there are sanctioning measures for SMEs. You will see that I have made a rather eloquent list of them.

I think I have answered the various comments, I will now be able to talk to you about the corporate tax reform. I had explained that because of the general context, you had forgotten the negotiations, that the State Council, unfortunately, had to work under impossible conditions, and then the Parliament, which you did not respect. The opposition has shown you that, when one seeks to pass in force, it has a number of rights, derived from the Rules of the Chamber. Therefore, I invite you to think, for the coming months, to allow Parliament to work in good conditions. We showed that we didn’t want to block for the pleasure of blocking. Proof, we are here today to debate, which will not stop me from voting against the corporate tax reform.

At the same time, what is ⁇ unbearable and which makes Parliament unable to work will never have the support of my group or other groups of the opposition: working in a blatant manner, in spite of common sense, sitting on the fundamental principles, neglecting the remarks of the State Council and avoiding any form of consultation with the sectors concerned. I hope you keep the lesson.

We have a problem of divergence about the overall approach to this corporate tax reform. The Grail is a linear reduction of tax rates. You have repeated it, Mr. Minister, in replica: the goal of the government is to create a climate. You’re doing climatology, “tax weather.” With this climate, you think, there will naturally be an economic dynamism. We mentioned the fact that there are a number of studies, ⁇ in English and American literature, that show that there is no direct link between corporate tax rate reductions and economic dynamism.

Economic dynamism is fundamentally linked, in a decisive way, to a whole series of other parameters: the quality of the economic fabric, the international environment, legal certainty, social peace, but also the investment in research and development, the training and quality of workers, in terms of their training and qualification.

In short, so many parameters that contradict the "fiscalocentrism", consisting of believing that fiscal policy alone can solve the issues of economic relief. However, we are far from counting, as most serious studies show. This does not mean that there is no need to think about a tax reform. Rates are one of these parameters – but one among many others. We have suggested that you think differently and continue to develop an incentive tax policy – one of the four major functions of tax policy – that allows you to link tax reductions to precise economic choices: investment, job creation, research and development. In other words, all these endogenous parameters contribute to an improvement of the economic tissue with the support of public authorities. In addition, this is what you do in several sectors through the famous salary subsidies. This has even motivated other policies. Now, in the field of taxation, you say that you will reduce rates and that thus the machine will be restarted. We have proposed you to be much more subtle and to develop a differentiated approach.

Your corporate tax reform, as it has been said, lowers rates – 5 billion euros – and provides for budgetary compensations through the removal of various deductions, exemptions, etc. The problem is that, in this way, you also remove meaningful provisions. I think, for example, of the exemption for additional personnel. This measure applies to ETS and provides for a tax reduction in case of commitment. The TPE, with whom we had the opportunity to discuss, explained to us that this provision suited them wonderfully. In addition, it has some sense for a relatively marginal budget cost. You have decided to abolish it.

Similarly, the investment deduction has been deceived because you updated it before deleting it. However, it also proceeds from an approach that aims to link the tax deduction to a concrete act: that is, a productive investment, itself generating value and providing jobs. You have also decided not to take this into account.

We also invited you to continue on the field of research and development. Unfortunately, once again, you have retreated. You have transposed Nexus, which consists of a renewed taxation of patent revenues. But, you must go much further, put the package to allow precisely our companies to increase their added value and earn, Mr. Bogaert, export shares. Indeed, it is through the quality of our products that we will help companies in this regard.

It is also by excellent training of staff in companies, to enroll them in a dynamic of research and development, that we will be able to create future jobs. Beyond jobs directly related to research and development, there are all indirect jobs. Look, for example, in the pharmaceutical industry or in a whole series of other sectors! The key is here! We support research and development. You have the power to do this, Mr. Minister. Unfortunately, you will still be frightened from this point of view and that is a pity.

There is, of course, the ground of budgetary neutrality. This is a ⁇ important area. We know, the National Bank repeats this constantly, you have chosen not to finance the tax shift in its entirety. This is in contrast to the National Bank’s forecasts. The non-financing of the tax shift artificially inflates the National Bank’s forecasts. She says it in an August 2017 note: "From the time when there is still a lack of 4.7 billion euros of tax shift financing, I am not able to tell you that my analysis is not biased." She says: "My analysis is biased." Basically, the budget bubble artificially inflates the National Bank's forecasts on the field of employment, available income, anything you want.

We are also suffering from the attacks of the European Commission, which says, “You lack 2 billion in the budget.” The opposition says: “To these 2 billion, we need to add some measures, whose estimate of budgetary performance is not sufficiently supported, for more than 1 billion euros.” While you are warned that you are missing 3 billion euros, you are committing to a corporate tax reform of 5 billion.

You tell us, "No problem, it is funded." Let's look at funding! For notional interests, you expect, in cruise speed, 2.3 billion euros. You make a bet, ⁇ based on forecasts, but a bet, betting on the fact that in three years, the rate of 10-year loans will increase. If I speak of the 10-year loan rate, it is the rate at which the notional interest rate is supported.

Then you say to us, “I know what the European Central Bank will do.” And to the question you’re asked, you answer: “It’s not unreasonable to think that rates will rise.” If the challenge of this bet was about a few tens of millions of euros, say even 100 million euros, on a wheel of 5 billion, we would say that you will find a new measure. For example, an increase in the soda tax competing for 75 million to fill the hole. We have been accustomed to this since the beginning of the legislature.

You are not avid in terms of creativity for household taxation or for social security savings. For that, we can trust you. But on 2.3 billion euros, if you plant yourself, even if only half – a billion – where will you look for it? We know it. In the social security budget that has become your cashier. This is where once again you will be looking for the money that you are missing.

In the bottom, if you have to retain something from your policy, it is about making reforms not financed and then you find yourself in the budget conclave with the finding that there is a shortage of billions. “What will we do? “Bah, we’re going to put some diesel excise, a tax on lemonade...” I’ve even heard people, not you, who are considering putting a tax on meat. I think there are people in your party who say that you have to do it! In short, taxes on people, or public services and social security.

The problem is there. And that’s why we don’t want to join your corporate tax reform project that is based on betting, speculation, prophecy. When managing public accounts, one has no right to be so unpredictable and so imprudent. We know what risks await our fellow citizens if you eventually do not find your funding. If it turns out, in the analysis of the results, that you are missing a few billion, we know where you will go to find them. This is why we do not trust your figures on the budget level. The facts give me the right.

On the ATAD, you expect 1.2 billion. I really invite all observers to read Mr Vanvelthoven’s speech on the ATAD issue, i.e. the directive aimed at limiting the tax erosion of the taxable bases, in particular the phenomena of tax evasion. You are expecting 1.2 billion.

Mr Laaouej, I give the floor to Mr Van de Velde.

Mr. Laaouej, allow me to refer to the financial situation that you have. In fact, you assume that we do not ⁇ it on a budgetary level. I have some comments on that.

First, the National Bank has done its homework very thoroughly and has shown that there is absolutely no difference between the assumptions of the government and those of the National Bank. This means that the current corporate tax reform will be budget-neutral.

Furthermore, from the hearings at which you were present, in relation to the ratio of the percentage of the corporate tax to the gross domestic product, the following has been shown; I have, by the way, made this historical record explicitly included. The corporate tax reduction in 2002 under the purple government, which was accompanied by so-called returns, — which were likely, I dare not say it loudly, partly built on loose sand — was fully recovered in one and a half years. The dips in corporate tax are indeed purely conjunctual, therefore very little of a technical or structural nature.

Finally, I do not find it also irrelevant to say that history also sets the government right. A first tax shift was carried out, resulting in all sorts of economic effects. Now we see that our income is simply increasing, despite the fact that our tax burden has decreased from 52.7% in 2013 to 50.1% today. You don’t like to hear this, but it’s true: despite the falling tax pressure, our income has risen, even faster than expected. You claim that we have found a bunch of money in the social security. However, I dare to tell you that in terms of spending we are still exceeding the limits of what is permissible. In the future, we should definitely look at the expenditure, but ⁇ not the income.

Mr. Speaker, I would just like to point out to my colleague Van de Velde that with regard to the alleged budget neutrality of the corporate tax reform, his own party chairman stated that the corporate tax reform was aimed at reducing taxes. This even made one of the Trends.

In my opinion, if there is a reduction in taxes, by definition, there is no budget neutrality. In doing so, I believe that Mr. Van de Velde should respect the words of his party chairman a little more.

Mr. Speaker, to avoid any ambiguity, I simply wish to be able to answer Mr. Van de Velde, otherwise I will still occupy the tribune for an hour. No one wants the speakers to stay there.

Mr. Van de Velde, I will not reopen the debate on the evolution of the available income. We talked about this during our budget work.

As for the 2.7% planned for 2019, according to the National Bank, it is already necessary to subtract from this percentage 1.1%, due to a whole series of decisions taken by the government in the field of taxation, consumption, due to cuts in certain health care. In short, there is a degradation of 1.1%, which annihilates the increase in the available income.

As for the good results, etc., I refer to the statements of the Director of the National Bank, Ms. De Wachter, according to which only a few thousand jobs – not a few dozen or a few hundred jobs – can find an identifiable cause in the tax shift.

In a ⁇ difficult budgetary context, one cannot afford to have a budget scheme based on medium or long-term forecasts. This is not serious! In any case, this is not what we did in 2002, for example. That year, the corporate tax rate was reduced with compensatory measures and taking margin. It was said that it was necessary to be cautious and that it might be cautious to provide for compensatory measures that exceed the cost of reducing the rate. Eventually, the facts gave us the right. We were approximately at the balance, or even a little above.

Here, with just two measures, you fund three-quarters of your corporate tax reform. It is not OK!

It is a transposition of a directive. But the Court of Auditors and the National Bank say together that you will only reach 1.2 billion if you transpose perfectly, fully and ambitiously, by choosing the broadest and best options, the famous directive. We are far from counting.

You say that the National Bank has done the study and the compensatory measures are tied to the notional interest of 2 billion euros, and to ATAD for 1.3 billion euros. You say that one makes a ⁇ optimistic hypothesis regarding the notional-interest rate.

The National Bank says about this: “As for the interest hypothesis for determining the rate of notional interest deduction, work was done with the mid-term outlook of the Federal Planning Bureau of June 2017, which is highly defensive. On the contrary, the hypothesis of a cross-speed interest rate of 2 % can undoubtedly be labeled as cautious.”

This was also explained by the Governor of the National Bank in the context of the objectives of the European Central Bank, which wanted to keep inflation at a minimum of 2%.

As regards the ATAD Directive, it is not about the Directive as such, but about its application. The Minister also spoke about this.

The National Bank said: “Furthermore, the application of the ATAD Directive is expected to result in a significant increase in revenue. The estimates used in this regard are consistent with the European Commission’s estimates of potential additional revenue in the European Union if there were no more profit shifts, which indeed requires that the ATAD Directive be rigorously transposed into the tax legislation of all Member States.”

You are right, but the minister has also said a few times that he will use the most stringent interpretation in that conversion, which is also stated in the texts. You doubt it, rightly. I also read a few things about this in the press.

I also had questions about funding. You know that too, Mr. Laououej.

It is about financing the whole reform. The National Bank says in connection with the notional interest hypothesis and the ATAD Directive that there are a number of guarantees, although uncertainty in those matters is always an element.

Mr. Chairman of the Finance Committee, one can have respect for the work and analysis of the National Bank and yet be critical, what we are. We found this analysis ⁇ pleasing to the government for various elements, including the two elements you just cited: the approximation of the future cost of notional interests, which finances 50% of the cost of this reform of 5 billion euros – with a future hypothetical tax expenditure, a real cost is financed – and on the transposition of the ATAD Directive against tax evasion.

On this second point, I would like to quickly develop my reasoning. I did it in commission and I will do it again because I have the impression that you have not listened. Europe offers two ways for States to transpose this directive: a minimalist path and an ambitious path. Almost all European countries have chosen the ambitious path. Belgium has chosen the minimalist path, with a reversal of the burden of proof, that is, it is the tax services of the Belgian state that must prove that there has been in the head of the companies concerned a will to avoid tax, of non-payment of the tax where they realized profits. It is often the pot of land against the iron port, you will admit. Why not have chosen the full version, with a requirement for the companies concerned to justify their choices? There, there would be a real capacity of our services to ensure that they actually pay the due tax.

There is a trick to transpose a minimum and to consider revenues to the maximum. This is one of the extraordinary weaknesses of your text, especially since, according to your budget tables, the transposition of this directive – which is in any case mandatory – will generate a fifth of the cost of transposition. Many very serious analyses show that the way you do it will allow for tax evasion again and again. There is hypocrisy about this.

Mr. Van Rompuy, the National Bank also told us that it had been working on a static model that comes from the SPF Finance. This is not a reproach, but it is not the SPF Finance to make large macroeconomic projections. There is also a problem of mischief in the way you bring us this corporate tax reform project. Wouldn’t it have been useful to put in place a model of macroeconomic simulation worthy of that name that allows to measure the effects of your reform on the budgetary aspects and on the aspects of redistribution within the economic fabric itself between small and large enterprises, between the different sectors of activity? You did not do it. Wouldn’t a simulator have been needed to integrate, on the basis of analyses and parameters, the change in behavior of economic actors, i.e. to measure the sensitivity of economic actors between tax increases, tax cuts and certain types of investments?

German studies, for example, show that there is a very special sensitivity to intangible assets, even from a 1% reduction or increase in taxes. You may have intangible asset relocation, that is, anything that produces high value added in research and development. The National Bank is not talking about this.

Couldn’t you have given the National Bank or the Plan Bureau the means to put together a model of evaluation? You did not do it. Why Why ? Because you did not spontaneously ask for the opinion of the National Bank. You asked it because at some point, the opposition put the problem on the table. We need to remember this and I can find you all the traces of our discussions. In essence, what concerns the National Bank is true for your entire methodology. You move forward until someone tells you, “Attention! You should think about this or that.” You have thus placed the National Bank in the impossibility, due to lack of time and resources, to carry out all its estimates. There are plausible hypotheses. Even though they are plausible, they remain no less hypotheses. On a 5 billion wheel, it is not satisfying to only work on assumptions.

Furthermore, as I said earlier, there is no consideration for the change of economic actors. I mentioned a case on intangible assets. I can read what the Court of Auditors said on page 25 of its report. She tells you, “Attention, your budget estimates are based on 2014 figures.” You are already four years late.

When you know how the corporate tax base works – it is ⁇ connected to the economic context and depends on the international environment (economic, fiscal, legal and even geopolitical, because an increase in raw materials has a direct downward impact) – you do not consider sufficiently these parameters that would have led you to present us with a more serious and a little less messy work.

I pointed to the National Bank, but it did not respond. She makes international comparisons between Belgium, where corporate tax equals a certain percentage of GDP, and Germany, where it is more. Except that in Germany, there are a number of companies that are not subject to corporate tax but subject to natural persons tax. Comparisons are biased. For all these reasons, we will take the opinion of the National Bank for what it is: a formulation of hypotheses. She tells you, however, implicitly to be careful.

Beyond the National Bank, whose business is neither taxation nor even budgetary control, there are other opinions such as that of the Court of Auditors, for example, which tells you to pay attention to your corporate tax reform and which reminds, in particular, that on the ATAD, the 1.2 billion on which you count will only be verified if you optimally transpose all the measures of the directive, which is far from the case. Some will come back.

As for legal certainty, State Council opinions tell you that there are explicit spaces for appeals – some actors you have neglected, such as the UCM, will benefit – and then there is Europe. I asked you, Mr. Minister, if, prior to the adoption by the government, you had notified some of the measures related to European law to the European Commission to ensure that there were no difficulties? We talked about the case of deductible dividends (RDTs) linked to your new deduction basket.

You told us that you exchanged with the European Commission and did not receive a negative signal. Again, electronic exchanges with certain members of your office and with the European Commission will not exempt you from a response from the European Commission if it considers ex post only in the implementation of your reform and in some cases, certain European directives are not respected. I think in particular of the Mother-Filter Directive, to take this example.

There should also be caution.

Another point worries us very much. We consider that it may be the cause of a budget hole without ground. This is fiscal consolidation. These are again only assumptions and forecasts, which suggest that you have a perfect control of the financial statements of all companies that enter the perimeter of tax consolidation. You indicate a cost of 500 million euros.

Is there anyone serious enough to consider that this figure can be taken for cash, if I can afford this expression? No one has knowledge of the financial statements of all companies present within the scope of tax consolidation. On the other hand, fiscal consolidation, which is a big claim, not of SMEs, but of the FEB, is a new toy in the hands of tax advisors of all hair, and in particular those that develop in large international groups. You give them a new tax roll to plan the state of their taxable base. These groups will be able to make sure to pay less taxes this year, by locating optimally, here the profits, there the losses. You have created a new tax engineering space.

The fiscal consolidation requires a second observation.

Mr Van de Velde asks for the floor.

Mr. Laaouej, I find it incredibly strange that you make it seem that the FEB, for which this government is making efforts, is something dirty. On the contrary, it seems to me. I think the government is making efforts for the entire economic field. This government also provides for a company law that is transparent and at the same time balances all actors against each other in a normal way. It also makes a very important effort for smaller entrepreneurs.

In addition, I would like to remind you of the following.

You have taken the word hypocrisy into your mouth. I do it now, even though I would not have done it if you had not done it. The hypocrisy of your hypocrisy is that you have been the inventor of the excess profit rulings. You wanted to break the hypocrisy regarding the high rates by giving the big companies a sort of escape clause. Mr. Laaouej, you are talking about hypocrisy, but I find this a staple of very punitive hypocrisy. This government is not involved in this. Here a complete field in the field of corporate rates is logically constructed. This is much better than what has ever happened in the past.

I don’t feel like I’ve called you a hypocrite, Mr. Van de Velde. I find, on the contrary, that you express yourself with great sincerity, that you always display clearly your opinions and even the interests you defend. This is not a reproach; on the contrary, you have the merit of franchise.

Beyond this, you talk to me about a number of measures, and I will talk to you about another: the fairness tax, the minimum tax. What did you do? Why didn’t you keep it? You tell me that the basket will have the same effect. We are not sure. A number of calculations have been made to show that, too, it is a new steering wheel for tax engineering and, from today, tax experts are working to be able to use it optimally. You have created new bidules, which already allow tax advisors to see how they will adapt best to pay as few taxes as possible.

You presented this corporate tax reform to us in this way: we will lower rates and in exchange, we will remove tax niches and tax deductions. Except that you have created a series of measures that will allow to re-engineer engineering. Furthermore, regarding tax consolidation, an employee of the National Bank replied to me that there was no risk. However, this is my reasoning.

The transposition of the ATAD directive, which contains some elements of the so-called BEPS measures, allows to bring back the taxable base in Belgium according to the principle that one must be taxed where wealth is produced. We consider that you are not going far enough, but we will come back to it later. With the tax consolidation, you return from the taxable base to Belgium and, therefore, the base you have transferred will ⁇ produce a loss of accounting or tax nature elsewhere. Well, through the consolidation, you will be able to re-impute these losses on the taxable bases you had brought back to Belgium. This is a white operation. In other words, what you earn on one side, you get back on the other with tax consolidation. That is my prognosis.

I admit that this is just a prognosis. That is why I commit you, on the whole of your corporate tax reform, to put in place a monitoring: five billion euros, it deserves a monitoring!

Mr. Minister, it is up to you to quickly set up, with your colleagues in the Budget, with other members of the government and administrations, the Supreme Council of Finance, the tax administration, ⁇ the Court of Auditors, a monitoring of the assessment of the positive and negative budgetary impacts of your corporate tax reform.

Every year, we can see what happens. And every year – I make an appointment with you – we make the point again. This is, I think, a way to make good politics. Can you take this commitment today in front of Parliament? This is an explicit and precise question.

There would still be much to say, in particular on provisions for risks and charges and their taxation in principle. This is something that I do not understand at all! There is here a accounting reality that makes that in the face of charges that are certain but of which we can not yet estimate the amount, companies, and especially SMEs, organize to deal with it: "not this year but next year" and build provisions from year to year, and then once the charge arrives, we had provisioned, kept internal financing, we use it. And at that moment, indeed, the burden is engaged. You are taxing from the beginning. It is incomprehensible! Again, this is an anti-SME measure!

Here are my colleagues. I will not be longer.

I thought I might be going to read the report of the National Bank!

Dear colleagues, you are driving the country into a new budget adventure – one more – even when you have created the conditions for budgetary precariousness! We’re talking about five billion, you tell us that it’s funded, we don’t believe it!

We consider that you have not put in place all the necessary in terms of consultation with the relevant actors. It would have been necessary to wait for the request of the PS group, supported by the other opposition parties, to obtain the hearing of the Union of Middle Classes in the conditions known where, rather than being heard and respected, the speakers were insulted. I repeat, this is unacceptable!

You also did not allow Parliament to work in the best possible conditions. It is ! We worked day and night so that we could nevertheless analyze the different elements properly. I want to thank all my colleagues, both the majority and the opposition – I mean that members of Parliament are not responsible, even those of the majority, for the improvised work of the government! But obviously we have more freedom to say it to him than you do – and I am convinced that I am here making myself the spokesman of many of you.

We consider that we lack estimates of the macroeconomic effects of this sector-by-sector corporate tax reform in order to see who wins and who loses. When such a reform is undertaken, we must be able to inform ourselves.

We also appreciate that you have decided to break with the incentive vocation of taxation, which allows it to function as an instrument of precision in the aid of certain economic behaviors. Whether it is productive investment or job creation, you are developing a new approach.

Furthermore, we believe that you are not sufficiently ambitious in transposing EU directives aimed at counteracting the erosion of the tax base.

In short, for all these reasons, we cannot join your company tax reform project. It has not been undertaken in ways that may help us measure the relevance of your choices.

We will vote against your proposal.

It is a great honour to be here today for you in this Christmas atmosphere.

I would like to thank all my colleagues, both from the opposition and the majority, who have made this possible. Let us not forget that a significant part of the work had to be done effectively in Parliament. Despite the hard work the government has done to prepare all the documents, which were surely and surely on time, there has been a struggle in Parliament. I do not mind either. I have stated from the outset that such a major change in our legislation requires a thorough debate.

Colleagues, although I don’t take the word easily in my mouth, what we do here today is historic. The change in corporate tax that this government is implementing, the way we simplify and make ourselves more competitive at the same time, is unseen.

If we take a look at what this government has already achieved in a few years, I must say that this is already an important step forward. This government has brought far more than it could ever have promised. I think not only of the tax shift I and the tax shift II that we will approve today, but also of the justice reform. Moreover, this government has implemented incredibly punitive reforms in the field of work and pensions.

Mr Laouej, it is true that such an agreement involves a precarious balance here and there. This leads to discussions where everyone tries to defend themselves in the best possible way. What we are experiencing here today is, in any case, a victory for Parliament. Let all the splashes of the past few weeks and months, this Parliament has had a very thorough and profound discussion of very important innovations and reforms.

Ladies and gentlemen, I would like to remind you of the context.

I would like to start with a black period, 2008-2013, marked by a deep financial and economic crisis that could perfectly have been the catalyst for necessary reforms. However, this has not happened. The government at the time preferred to tax heavier. While Di Rupo did not know his classics – never waste a good crisis – this government knows them. The government is fully engaged in the story of the cradle and the ants, because when things go well, one must also repair. We need to think and reform. That is what we do today.

The tax shift 1, including, by the way, the courageous index jump that was made then, resulted in phenomenal results. The purchasing power has increased. When all the measures in the tax shift are fully deployed, we will also come to an increase in the net salary of the lowest wages by 170 euros per month. I know this is very difficult for the left-wing opposition. That is an unlikely step forward that we have made for the lowest wages in this country.

All indicators were theproof in the period 2012-2013. Some colleagues would like to hear that all these indicators are bright green today. The growth is unexpectedly high, the payment balance shows a spectacular growth of exports, a growth of investments that next year if possible would be slightly higher than this year and especially a reduction of the tax pressure from 52.7% in 2013 to currently 50.1%. This country is economically in blinking health.

However, let’s not forget that there are also some alarm signals, for example, in the international field. International competition is hard.

The shift to e-commerce will also have an impact on what we experience in corporate tax in the coming years. We must be prepared for the shift to consumption, which will come. This reform provides a perfect answer. During the various debates, I have heard a number of colleagues talk about the race to the bottom. Well, that race to the bottom, dear colleagues, is not a wish of governments. The race to the bottom in the field of corporate tariffs is an exogenous driven process that one as a government must watch over. This is because a number of countries are organizing themselves today. The United Kingdom, in anticipation of Brexit, is lowering its corporate rates very dramatically and sharply. The United States is currently on the hunt for all possible exceptions in various countries, such as the notional interest deduction in our country, because they want to arm themselves more competitively and ensure that capital and investments take place at the local level, in their region.

Dear colleagues, this reform offers answers to international issues such as the notional interest deduction. I am convinced that the new form of notional interest withdrawal, in which we will work on the basis of the growth of capital, is much more correct than the current form.

At the same time, this reform also makes our companies more competitive internationally. We are – let’s not forget this – an export-driven, small economy that depends on what happens outside of us. If we do not make ourselves more interesting today as a location of establishment, then we will simply be overlooked. In this regard, this transparent and stable taxation is a major step forward. She was also very needed.

Now we come to the budgetary element. We have already talked about that. I can skip that point pretty quickly.

I am pleased that Mr Van Rompuy explained in a very erudite way that, according to the National Bank of Belgium, the government has based its change of the corporate tax on a very conservative model. The financing of the tax shift as an example has never been and has never been problematic. In that regard, we must also emphasize that the current government has not incorporated return effects into its model, which has happened several times in the past. I even think to know that the biggest measure in 2002, which was introduced with the previous reduction of corporate tax, was reversed by the Constitutional Court after two years.

Colleagues, we also held a very interesting debate on who now wins and who pays. This debate was primarily a search for a political weapon. Everyone here in the Chamber is convinced that the change in corporate taxes was necessary.

The highlight was the mistroost display during the hearing we held yesterday with UCM. She was mistreated, not because people say business or because an interest organization would defend her interests. She was especially mistreated by the misunderstandings and the lack of substantive debate, which in my view was unfair.

After all, the increase of the 36 000 rule is not new. UCM can advocate pro domo for its members. However, we believe that it is socially unfavourable that only for tax reasons autonomous activities exercised as a single-person business are associated. In this regard, I find your discourse very surprising, Mr. Laaouej, because in fact you are advocating the association of colour. In fact, you say that we need to maintain today’s situation, where people have chosen a corporate form for tax reasons. You are very flexible in your reasoning. Apparently, socialist has become almost a flexi-job today.

The government is therefore taking an initiative to enable self-employed people to build up a supplementary pension, such as business leaders in companies. That is much wiser than continuing to advocate for the association. The company, the legal form, exists for certain reasons. They are not there to seek a tax advantage.

In this regard, we must conduct a double reasoning. Of course, the load pressure in the personal tax should also go down and the only way to do so consists of effective savings. There is no need for a flight to a company. On the contrary, then one is happy that one can work and that one can be paid in a normal way. We therefore advocate a reduction in the personal tax rather than the evasive behavior through companies.

Do some establish companies or constitute themselves in a strictly fiscal perspective, excluding any other consideration? Yes, the problem is not new. There are ways to do this that are ⁇ aggressive. People create completely fictitious societies, which make the fictitious interposition of people. We are in tax fraud. The tax administration has to do its job. If it considers a company to be fictitious, it has various possibilities at its disposal, such as simulation. The simulation is a legal figure that can be mobilized by the tax administration. She does so regularly and she considers that she is not bound by the social reality, that she can directly interest people and tax income in the head of people. There are all provisions relating to tax abuse. There, we are no longer necessarily in fraud but we are in tax evasion, in tax abuse. A number of other provisions allow to combat the abuse of companies when it is done fraudulently.

In other cases of people who decide to start a company, considering that the first parameter is fiscal is a mistake. It is wrong to say that! The first reason, when talking with practitioners, when observing, when knowing the economic realities, I obviously speak of small ⁇ , is to protect the heritage or to create a legal vehicle that will allow a capitalization with associates who, each, will put balls in the company to make it work. This is also why some create companies: protect the heritage and create a structure that allows for financing.

For the rest, Mr. Van de Velde, I’m sorry but the legislator has not been waiting for you to make sure that the use of companies can only be used for tax purposes. The rule of €36,000 for obtaining the reduced rate was already a form of ⁇ significant constraint with regard to the constitution of a company. The 4x4 rule taxs a portion of the surplus value of assignment when someone who exercises as a natural person decides to constitute a company and bring his clientele and a whole series of assets that he owned as a natural person. It was considered that if the valuation exceeded a certain amount, there was a taxation. All of this exists.

And I can continue. A number of measures have been taken to avoid the creation of companies solely for tax purposes. As the Chairman of the UCM also said, it is unfortunate that you are suggesting that any constitution of a small business is made for tax reasons. You suspect everybody. But not ! If there are abuses, the tax administration can trigger certain devices.

The suspicion approach you are developing is pretty strange. I do not agree.

I think the discussion is of the job. In fact, we say the same thing: there should be no incentive to associate. This is not necessary in the corporate tax, but should also be removed from the personal tax. Once we think forward and possibly can take some steps in the personal tax, as in the Netherlands, that stimulus will be completely gone, I think.

The rule of 36 000 euros is absolutely not new, as you rightly argue. It was introduced in 1992. The amount can be discussed. I only see that during the period 2002-2018 both the minimum wage reduced corporate tax rate and the 50 % tax gap in personal tax were indexed each time. The current government does not do more or less than index the amount. One can then discuss the amount of it, but it is merely an indexation, nothing more.

This is not an indexation that you are doing, it is an indexation catch-up of several years. How many years, Mr. Van Biesen? Ten years, ten years of catching up indexation, is brutal! If you had said, “From now on, we will index to allow SMEs to adapt,” we would have understood. But, in this case, you’re catching up with ten years of indexation, it’s incredible!

I am beginning to understand the logic. Your argument is to index an amount that has not been indexed for ten years. Can you imagine the brutality for people? From day to day, you ask them to completely change the management, not fiscal but financial, of their company.

Small and medium-sized enterprises have also recalled this. Business bosses and small managers do not allocate remuneration or allocate low remuneration. They don’t do it for the joy of heart. They prefer to leave their money in their company to ensure its development. They give up allocating a large remuneration to leave liquidity in the company because it will need it. And then you say, “No, no, no! You must allocate at least 45 000 euros. Otherwise, you will lose the reduced rate and a penalty will be applied to you."I better understand the logic, but imagine the brutality of catching up over ten years! Index from now on.

It was indexes indexes. You’re referring to brutality, I’m referring to the hypocrisy of not taking that 50/50 ratio into the discussion all the time.

The critics, the people who criticize those 45,000, of course forget that it is written in the law that when less than 45,000 can be paid, the 50/50 ratio between the profit and the salary of the trustee remains and also entitles to the reduced rate. Those who don’t make a profit, do nothing. In this regard, all the balances that must be respected are indeed respected. It is not true that small and medium-sized enterprises will suffer a disadvantage.

What no one has noticed, until you just said it, is the removal of the maximum limit, the distribution of 13% dividend as a condition for the favourable rate.

Colleagues, let me be very clear, the SMEs and SMEs do not pay an account in this reform. SMEs and SMEs are moving forward. We should not, on the basis of one testimony by way of speech, organize a sort of avenue des misérables. No, this reform is there to help our ⁇ move forward.

I found the discussion we had with the UCM almost hallucinating. Now, suppose there is such a huge difference between the fabric in Wallonia, and Brussels and Flanders, let us simply split the corporate tax. Then arrange it yourself. Arrange it in your own way. Go ahead with your higher rates. just do it.

I assume that this is a favourable situation for all companies, both in Flanders, Wallonia and Brussels. Just look at the statistics and surveys: 87% of ⁇ in Wallonia support this reform. Mr. Laouej, you have to do your homework.

This reform with the global relance is, of course, much more than what we have heard so far from the opposition.

Mr. Van de Velde, you refer to a survey conducted with an independent organization. You compare this organization to the Union of the Middle Class, which is one of the social partners, and which is the most important representative of small and medium-sized ⁇ in Brussels and Wallonia. The latter told you that he considered that the Brussels and Walloon companies had not been put on the same foot as the Flemish companies.

This means that he asked you to take into account the realities of Brussels and Walloon. You make it a community problem. I take note of it. Tomorrow, you may explain to us that there is a little more rain in Wallonia than in Flanders, and that we need to regionalize the weather. Your obsession is somewhat this: any problem must have as its solution a regionalization, even operated in the most absurd way.

At the European level, the European tax harmonisation is debated. It seeks to establish common tax bases and common rates, in order to ⁇ convergence and avoid tax competition within Europe. You then present considerations of this nature, which reflect, in the essence, the lack of vision that you have about taxation. I was explaining it recently at the tribune: your corporate tax reform does not take place by considering all economic parameters, such as the tax base, the international environment, the practices at the European level. Instead, you present us every time the little bit of the dwarf. You produce numbers that do not represent anything. The problem is here, Mr. Van de Velde. We ask you to reflect a little before carrying out this corporate tax reform project, but you continue with your narrow policy arguments, which are not at the height of the issues.

You attended the hearings of the Union of the Middle Class yesterday, like me. You have heard his responsibilities. I still think that you don’t want to hear them or listen to them. I am not talking about the figures, which the debate will continue on.

They said, with heart, things that should concern you, economic realities. You know, the Wallon and Brussels companies also have for customers, and especially for suppliers, other companies, whether in Flanders or elsewhere in Europe. Can you imagine that we are in a closed vase? Can you imagine that economic flows and circuits stop at the linguistic border? I can refer you to the study of the Iweps, a Walloon Institute of Prospective Studies, which shows how much of their wealth and added value is derived from what they sell and provide in Wallonia. Do I need to remind you how different regions of the country are interdependent? Brussels is a pool of employment of more than 700,000 people, in which many Flemish workers come to work. Mr. Van de Velde, take a little height and don’t be a prisoner.

Mr. Laououej, you surpassed the two minutes agreed.

I believe that communitarianising the debate as you do is really skipping the issues and discussions we have had. This fundamental debate concerns all entrepreneurs and entrepreneurs in this country. It is really a shame to make it a community issue because it does not have to be.

The UCM represents who? It represents all TPE, SMEs and self-employed persons in this country.

In Belgium, today, there are 899 223 SMEs, of which more than 80% employ no employee and 14% one to four people. It is for these companies that we are fighting. It is for these companies that we are speaking to tell you that UCM and UNIZO have long demanded a tax reform, a relief of corporate tax, the nominal rate.

But this does not mean that the reform that is being submitted to us pleases them. Indeed, through a whole series of devices that you are planning – I think here in particular of all those companies that employ less than five employees – you are making them pay the reduction in corporate tax.

This is the issue that is debated. The UCM tried to demonstrate this by graphs, yesterday, in commission, demonstrating that you swept from a reverse of the hand by saying that the calculations were false. Show us some other calculations. This is what the debate is about. It does not concern all companies in the country, but the target heart of our SMEs and our self-employed.

One figure seems to me ⁇ interesting when one tries, like you, in vain, to dilute the community smoke screen. Today there are 79 SMEs per 1,000 inhabitants in Belgium, 84 in Brussels, 83 in Flanders and 66 in Wallonia.

Small and medium-sized enterprises are the strength of this country. And there is no question of saying that a measure must be developed for Flemish SMEs, a measure for Brussels SMEs and a measure for Walloon SMEs. No one asked for it, except you now!

By doing so, you are skipping the challenge, namely how to make an effective tax reform and which encourages small structures that are the vast majority of our SMEs, our TPE and our self-employed.

Monsieur Van de Velde, si vous ai bien entendu, vous avez assimilé l'audition de l'UCM à un boulevard des misérables. Here, another member eminent of the majority is the qualified of the communists. For the Flemish parties of the majority, the UCM is the union of miserable communists. You really regret that, in this majority, there is no French-speaking party to defend the legitimate interests of wallon and Brussels companies!

I find this whole debate very strange. I think that some parties will still have to eat some butter hammer before they can present themselves as a credible business party, especially when they do so on the basis of data that is incorrect.

Mr Dispa, you put your finger on the wound. What is it about? This is not the boulevard of the misérables. We do not say that they are. No, it is about the way this leftist opposition tries to present it as le boulevard des misérables, but that is of course not the case.

If you are raising someone who needs to come up with numbers to prove that what we do for small and medium-sized enterprises does not work, make sure that he has good numbers and that he can prove his right, instead of and telling a total wrong story. Your policy is the disinformation, which you try to flood through all sides and make you think you are enterprise-oriented. You are not that at all. That is shameless. I found the discussion we had with Mr. Laaouej the right discussion. You should make sure you do that with supported numbers and tables.

We’re going into the discussion with all pleasure, but continuing to say that it’s the small ⁇ that will pay for this story is wrong. That is a lie. That is not correct. You can continue to do that, but that is pure disinformation and that is the way you do politics.

Yesterday afternoon, there was a numbered demonstration, supporting table. You have said yourself, "Go sit down with the Van Overtveldt office, so you can compare the numbers." Where are these numbers, where are those calculations?

The important aspect of this reform is in relation to this public, the very small structures, which often have difficulty connecting the two ends. It is this public, which creates sustainable and non-delocalizable employment, that must be encouraged.

After yesterday’s hearing, there are doubts about the effectiveness of the measures being taken for a part of this audience. The question is not about interest rates but about compensatory measures. You can say it’s fake news, you can say it’s disinformation, it’s a smoke screen when you no longer have any argument.

I say this to you on the basis of yesterday’s afternoon hearing. The UCM proposed a numbered chart. I am not saying that this is the absolute truth, but it is an important basis for discussion. You are saying that the UCM is the last of the idiots, which presents us with false numbers and practices disinformation.

There is apparently no longer anyone in this government to defend SMEs and self-employed and that is regrettable. We can consult the written report to find out what has been said but it is not what you are reporting, Mr. Van de Velde!

Let’s be serious, let’s have a clear debate on numbers instead of making smoke screens that don’t serve the public debate!

Mr. Speaker, I will ask a very simple question to Mr. Laaouej. Mr. Vanden Burre was also present in the committee, but he lies here that he sees black.

Mr. Laaouej, have we covered tables that contradict what the UCM has said?

You gave us pictures that were sent to us by e-mail and that we followed to...

He is lying!

There is no ping-pong. I am trying to conduct this debate. It is not Mr. Van de Velde’s responsibility to ask questions.

It is not Mr. Van de Velde who asks questions to other members who must then answer them. We will not do that, because it will remain a ping-pong game. Mr. Van de Velde continues his speech.

If you ask me for the word, Mr. Laouej, you have it.

Dear colleague, you cut off my speech before I finished answering.

Mr. Van de Velde delivered a number of paintings yesterday in commission, which came from him or the N-VA group or the cabinet, it is difficult to say. I asked to send them to the UCM by email. This was done between 18 and 19 hours, I think. This, in order to allow the UCM and the Cabinet of Finance to have a contradictory debate. I think I have said it quite often, we need a contradictory debate. This debate is still ongoing since around 10 o’clock in the morning, the UCM responded to the Finance Office and we were copying. The discussions are not over and the discussing partners do not agree. This is the current state of the discussion.

Mr. Speaker, I find it ⁇ painful that this debate is reduced to a casus, an example of a company making a profit of €86 000 and paying itself €36 000. This example has been discussed over and over again between the majority and the opposition here for a long time to get their right.

I can only tell you that I have looked carefully at both the figures of Mr Van de Velde and the figures of the UCM, and that they are both right.

He is not lying? (Referred to Mr Vanden Burre)

He lies because he says the numbers are not given, while the numbers are given.

Stop it now!

Mr. Speaker, I would like to return to the essence of the draft, in particular the reform of the corporate tax, without fixing ourselves on a single document nor on who at any time has said or expressed something showing that we would have favoured this or that. Let us return to the essence of the matter.

I agree with this.

Mr. Van de Velde, treating someone as a liar does not serve the public debate. What I said and which appears in the speeches and in the mail this morning is that a discussion is ongoing. A table was shown yesterday by the UCM, tables were exchanged by the cabinet and then? This is a version A versus a version B. Things need to be clarified. I would like you to withdraw your accusations, I find this process embarrassing in the discussion of a fundamental bill.

Then, the UCM, Mr. Van Biesen, is not just a case. It represents the vast majority of SMEs, TPE and self-employed persons in this country. The UCM conducted a survey, before coming to the hearing yesterday, with their social secretariat, covering all of their members. Do not say that this is a small case. This is a very concrete survey, for which they gave the average salary, which oscillates around 35,000 euros for the heads of Wallon and Brussels companies. They are representative. To deny it is completely incorrect. It is time for the government to resume. If we did this at UNIZO, Mr. Van de Velde, you ⁇ ’t treat one another as liars. Be respectful of the interlocutors who have presented themselves and let us have a substantive debate on the numbers! We are also demanding.

This is not a favor I ask. I ask you to speak in the usual and usual forms. This is not a favour, I just ask you to speak!

Mr. Laaouej, do we have an agreement that limits each interruption to two minutes, that one can only interrupt once and that we then return to the speaker? Either we have made that agreement or not. If this is not the case, me for a moment. If there is an agreement, I will stick to it.

Between my speech and that of Mr. Van de Velde, there were others. You will understand that I am perfectly in line with the rules that we improvised together this morning. Let us say things as they are! I do nothing but take the word again. This is not a favor you give. I am somewhat annoyed by this way of doing, I don’t hide it from you.

In short, Mr. Speaker, everything that is happening here is symptomatic of the government’s messy work. This is what is paid here today. If we had worked in good conditions, giving ourselves time to carry out the necessary hearings, analyzing this dossier in depth, comparing the figures, we would not be busy now, in the plenary session, sending us tables to the figure of one and the other.

The truth has its rights. The UCM considers that the figures held by the majority and the Cabinet of the Minister of Finance are cases that can be contradicted by other cases. Here is where they are! This is not the way a tax policy is conducted.

Mr. Van de Velde, you go back to corporate tax.

Yes, Mr the President.

I am pleased that this meeting is being recorded so that all colleagues can subsequently review what has really been said, right, Mr. Vanden Burre?

Mr. Speaker, colleagues, this reform and relance involve much more and are much broader than the discourse we have been speaking here for a while under the impetus of an opposition which, in my view, is somewhat loose. This reform is green in the field of automotive use and the investment that is possible in the future. This reform is also more social. That part follows. For example, I refer to the deduction for childcare for single parents who find it difficult to get a job. This reform stimulates the economic fabric in our country and above all this reform is future-oriented, because the relance also includes some opportunities for deduction of investments for future technologies.

Finally, there is now a corporate tax that puts its quotation aside and which is transparent and unambiguous for all economic actors.

Dear colleagues, I think this is a penalty five-chapter of this government. The history of the first tax shift gives this government right today: more economy by less burdens.

Mr. Minister, I will repeat it once again: you are the best money-back guarantee for all who work and have worked in this country.

Dear colleagues, I intend to continue the debate without lunch break this afternoon.

We will continue the discussion without interruption, unless we are prevented from continuing for technical reasons. Please take this into account.

Since 2015, the government has undertaken a strategy to revive our economy. The corporate tax reform was initially part of the broader framework of the Revitalization Act, a framework in which the government takes a number of other measures to boost employment, purchasing power and social cohesion. However, we are pleased to have reached an agreement between the majority and the opposition to concrete, before the end of the year, an important aspect of the bill on economic revitalization and social cohesion: the corporate tax that is the subject of our debate this morning.

This agreement is proof – if necessary – of the will of all to reform the corporate tax, beyond discourse, otherwise how would we have reached an agreement?

Other measures that complement this consistent set of economic recovery will follow very soon. We will have the opportunity to discuss this in January.

The corporate tax reform is a significant and ambitious reform that helps make our economy stronger. By implementing the measures contained in this law, we send a clear message and strengthen Belgium’s economic stability.

With the corporate tax reform, we are implementing a second important tax reform after the tax shift. It is historical and it was necessary.

This reform is primarily part of changes carried out at the European and international level. Today, we could no longer ignore the pressure that is exercising on these two plans. The strategic approach chosen by the government is to lower rates and expand the taxable base. This approach was welcomed by the National Bank.

On the one hand, this reform is part of a European framework where neighboring countries reduce their tax rates or plan to do so. With a nominal rate of 33.99%, Belgium applied the third highest tax rate after Malta and France. It was imperative to send a strong signal.

The government has therefore decided to lower the corporate tax rate from 33% to 25% by 2020, with special attention to SMEs – whether flamish, Brussels or Walloon – which will benefit in an accelerated way from a greater reduction of the rate. As of 2018, a 20% rate will be applied.

By reducing rates, we are getting closer to the European average of 21.9%, and we are increasing our attractiveness.

On the other hand, the OECD and the European Union are becoming increasingly aggressive towards niche strategies. It is important to emphasize that, in the proposed reform, most tax niches were directly or indirectly affected. Only the most important niches were preserved.

In this way, we will progressively ⁇ greater tax justice between large companies and SMEs. For Mr. President, this is essential.

In addition to the reduction of rates, other important measures are: the additional crisis contribution that will be reduced to 2 % in 2018 before completely disappearing in 2020; the deduction for investments that will go from 8 % to 20 % in 2018 and 2019; the progressive extension of the exemption from the payment of the professional prepayment for scientific research to undergraduates; tax consolidation, as well as the transposition of the ATAD Directive. Some measures seem less favourable, overall, for SMEs, but there was a need for a balance to bring the tax rate down to 20%.

It should be added that many other measures are being taken in favor of self-employed persons and SMEs. Among them, the lifetime exemption from employer contributions for the first job created by a SME between 1 January 2016 and 31 December 2020; the additional reductions from the second to the sixth job created within a SME; the establishment of the second pillar of pension for individuals. All of these measures are fruitful as 22,188 new jobs have been created thanks to the “zero contribution” measure.

Among the critics of the 20 corporate tax measures, three are major. I will not return to the dialogue with the UCM, we have already talked a lot about it. I find it a pity to place these debates at the community level, because our Walloon and Brussels SMEs ⁇ deserve much more encouragement and attention and they ⁇ have nothing to envy their neighbors.

In general, it is not constructive to take each measure separately. It is necessary to adopt a comprehensive vision, such as the tax return, and to take into account the context in which this reform falls.

Mr Piedboeuf, I am pleased to hear that you are partly disguising your colleague, Mr Van de Velde, about the communityization of the debate.

I would like to hear you about the remarks made by your colleague of the majority, Mr. Van de Velde, when he talked about the counter-truths and lies that would have been spoken by the UCM. I ask for your opinion because the debate held last afternoon in the committee on the representativity of the social partners, and of the UCM in particular, is important. Your colleague claimed yesterday that the UCM does not represent much and that they came to tell stories. We know, however, that UCM is the leading association that defends SMEs, PPE and self-employed in French-speaking Belgium.

It is obvious that we know all the importance of the UCM. We have been in contact with them many times. I told Mr. Nys, after the hearing, that we should meet again to talk about it.

I refer to what Mr. Van de Velde said. He talked about paintings. Yesterday, tables were presented by the UCM. We then considered the possibility of studying the issue more broadly. Several paintings were distributed and I examined them. They show income tranches and distribution. It is observed that in all the cases presented, a tax gain is achieved. It is necessary to optimize the situation of the company, as I noted at the UCM during the hearing, in front of the table presented. I was tried, mistakenly: I said that it was necessary to change the tax advisor because, on this table, one can optimize. Anyone in the face of such a table will consider that adjustments are probably possible.

Mr. Van de Velde spoke of a lie. You said that no paintings were distributed. There were, and we have seen them. I learn that a consultation is taking place on the subject and I look forward to it, even though it is late.

The [...]

No, it’s not too late, Mr. Laououej! We will vote on a 20% rate for SMEs and that is important.

Now on to communitarianization. This was discussed in the committee yesterday. It is said that Walloon and Brussels SMEs experience lower income rates. The economic fabric should be properly studied. Some small and medium-sized companies in Wallonia and Brussels are extremely successful. That there are more small independent workers, small societies, it is possible, but we must defend our fabric and refrain from miserabilism. To bear archery on this element is to demonstrate miserabilism. We must defend our Regions, both Brussels and Wallonia, with force. All the measures we take to defend SMEs go in this direction. We must be proud of our fabric and fight for it. It is true that more and more Flemish companies are coming to settle in Wallonia, in the province of Luxembourg. I am one of the defenders. They come because the fabric is favorable, the land is cheaper, and it is possible to develop an appropriate economic activity. Let us defend our heritage instead of making miserabilism!

This is exactly what we are doing! I applaud the last words you said. I have no problem with that. All that has happened in recent years can only show that.

I just wanted to intervene with regard to the credibility and representativity of the UCM that was questioned by your colleague. I think this is quite problematic for the majority. The UCM conducted a study, a poll, through its social secretariat, on its own members. It was on this basis that the painting was created. We’re not going to turn around the pot for 200 years. What your colleague here, a member of the majority, with you, says is that she came to tell salads and that she represents only one case and that she’s not – that’s not said literally, but I translate – “not credible.” With that, I have a real problem. She is credible! He conducted a poll with his members. I wish someday that someone, in that majority, could put things in their place. I would also like to hear from you about the commitments. You are talking about consultation. Obviously, it is too late, but what are you committed to in relation to this negotiation?

The credibility of the UCM is not in doubt, as is its seat at the level of wallon and Brussels companies. But when we talk about the corporate tax reform against the minimum income of €45,000 and when I ask the question of what the UCM thinks of the 50/50 rule that obviously is eminently more favourable to SMEs, I have no answer.

I take the example, to reason with the absurd, of a company which, if it gives 10 000 euros to its executive and declares a profit of 10 000 euros, benefits from the reduced rate. We are no longer in the 45,000. It is said that in this case, it benefits from the reduced rate. What are I answered? “Do you think you can live with 10,000 euros?” is not that reasoning! Reasoning is reasoning by the absurd.

On the other hand, the door was opened for discussion. There are, as you say, already exchanges with the cabinet. We will, of course, go back to listening to the UCM, as we do very often in relation to a whole series of other measures. Then we will see if the legislation needs to be changed. It should also be said that in the programming, there are deadlines 2018, 2019 and 2020. If we have made mistakes and if we find that there are mistakes, we can also make things change.

I return to what I said. Generally speaking, it is not constructive to take each measure separately. It is necessary to adopt a comprehensive vision, as is the case for tax declaration, and to ensure that the context in which this reform enters is taken into account.

With a careful study of all measures, the tax situation of SMEs is significantly improved. Very few will be those who might not find an interest in it. Transversally taken, the reform lowers interest rates and fights against fiscal niche strategies.

As we know, the status quo would have been considerably negative. In a small country like Belgium with a small open economy, this need has been mentioned many times in the Finance Committee by all parties. Without reform, we would risk a considerable loss in terms of competitiveness, employment and investment. This reform will make our country more attractive and legally stable at the level of its economic model.

Finally, at the budgetary level, we must keep in mind that the return effects have not been taken into account, and we know that they will be largely positive for our economy. The National Bank confirmed that we can expect positive dynamic effects. Considering the potential effects in the medium and long term, and therefore overall, on the recovery of our economy is essential.

Mr. Speaker, Mr. Minister, dear colleagues, for our group, it is of paramount importance that the government continues its structural reforms in order to continue to promote economic growth, employment, purchasing power and social cohesion.

The corporate tax reform plays a key role in this regard. It is a reform that meets imperatives. We are fully aware that we need companies that create jobs. With this reform, we revitalize and maintain an important economic activity in our country. The reform also allows, and above all, more tax justice between large companies and SMEs, which the MR fully supports.

It is therefore with enthusiasm and conviction that our group supports the reform of the corporate tax.

Mr. Minister, colleagues, we are very pleased as the CD&V group that we can finally vote on the corporate tax reform. For years, even before Minister Van Overtveldt took office, we have been asking parties to make our corporate tax fairer for SMEs in relation to large companies. We wanted an expansion of the taxable base and fewer exemptions and deductions. We also wanted to make corporate tax more competitive and give our companies more oxygen so that they can again create jobs and prosperity. Finally, we wanted to maximize the corporate tax support for innovation and research, always for growth and high-quality jobs in our region.

The Belgian corporate tax has been characterized for years by its niche taxation. It has historically been built around a high nominal rate with various items, deductions and systems to lower the real tax rate. In the meantime, however, we have known for several years that this system is under pressure, not least because of the European rules on state aid. In addition, the rules are increasingly harmonised at the level of the European Union. That is a good thing and we stand behind it. Furthermore, there are increasingly recommendations from international bodies such as the OECD, think about the BEPS Action Plan. This evolution forces Belgium to partially revise the historical strategy of tax niches in corporate tax.

The Belgian corporate tax rate is one of the highest in the European Union and OECD. That situation is no longer to be ⁇ ined, according to the government and also according to CD&V, as several European countries are working on a reduction in the rate of their corporate tax, but think of Ireland where this happens in extreme degree, the United Kingdom and also the Netherlands, close to us. Without intervention, the government and CD&V threaten to lose competitiveness and the associated jobs and investments. Government revenues would be under pressure not only directly through corporate tax, but also indirectly through other sources of income.

The aim of the current reform is, therefore, to seek a simplified system — it is in part already more simplified, but not yet where we want to get — with greater legal certainty and justice.

This objective is achieved by reducing the current rate and thus financing it through the expansion of the taxable base. Therefore, a number of specific regimes that have been built in the past, such as certain deduction points, may reduce or eventually depletion in the long run. The few options remaining to reduce the actual tax burden are ultimately more closely linked to what we call the economic substance or also the economic reality and business operation. In this way, however, the emphasis will be placed on specific deduction points that stimulate employment and innovation, including once again the extension of the exemption from the transfer of corporate fee for researchers, which we find a very good thing.

The Belgian government still has a budget deficit. This reform, through new investments and the resulting employment, aims to contribute to the sanitation of public finances. Therefore, it is actually also, internally in the corporate tax, a tax shift. According to the Minister, the budget neutrality was calculated and the achievement of that goal was measured. Indeed, we have requested the advice of the National Bank, in order to be able to test this important reform of budget neutrality. After all, we do not simply want to carry out the corporate tax reform, ⁇ not if it would pose a risk to our future income and the security of public finances.

The National Bank’s report, which was presented to and explained in the committee, has given the advantage of questioning this corporate tax reform in terms of budget neutrality and indeed states that there are clear risks upwards as well as downwards associated with the reform in question. As a precaution, the Minister noted that the effects of return on earnings from new investments and jobs were not taken into account, as well as the likelihood that a standstill scenario would have massive negative effects on economic parameters and public finances. It is also true that we now see a number of years in a row an increasing evolution in the revenues of the corporate tax. This is a good time to implement the reform.

Mr. Minister, as already stated in the committee, CD&V will give confidence in the corporate tax reform. However, we also rely on the monitoring of the reform in terms of the effects on revenue and expenditure. It should not be that the long-term reform creates a hole or additional hole in the public finances.

The building blocks for a new corporate tax are now known. The nominal rate will be reduced in two phases from 33% to 25% from 2020. The additional crisis contribution is fading: first it will be reduced to 2 % in 2018, then it will be abolished in 2020. During the reform, we had a lot of attention for small companies. For them, the rate will fall to 20 % from 2018 for the taxable basis of the first 100 000 euros. We would like to be able to immediately implement a significant tariff reduction for small companies from 2018. In this way, small companies could soon benefit from a reduced rate of 20 % on the first 100 000 euro discount.

We therefore hope that for small and medium-sized enterprises the corporate tax reform may be an additional push in the back, for us always with the aim of creating additional wealth, added value and jobs. After all, that remains the motto of the current federal government and the motto on which CD&V entered the current federal government. Our leading motivation is the creation of jobs, growth and prosperity.

A number of special tax favorable measures will disappear. However, some existing assets will be preserved or reinforced. In this regard, I refer again to the scheme for encouraging investment and innovation.

I come from a city that has a large number of biotech and pharmaceutical companies, just think of Janssen Pharmaceutica and Genzime. I can see and experience in my city and region how important these regimes are for innovation and research, not only in terms of employment but also in terms of added value, value-added creation in a city and employment. We are therefore very pleased that these regimes are still being strengthened by the reform. Fiscal support for the audiovisual sector and the performing arts will also continue to exist due to the direct employment effects.

I will not go into detail on the various measures. I conclude that globally, this is a positive and reinforcing reform, which we can and should support.

In addition, in the margin of corporate tax, a number of measures provided for in the draft law concerning the relance, such as the introduction of the increased investment deduction for self-employed persons, the possibility for self-employed natural persons to obtain an increased professional deduction. We find that there has been a lot of effort in the segment of self-employed natural persons, in fact, to be able to counter corporate establishment at a reduced rate of corporate tax and also give self-employed natural persons all the opportunities and oxygen they deserve, to contribute to growth and job creation.

We therefore welcome this reform with pleasure and hope for soon additional recruitment and new prosperity in our country. The situation is constantly declining, Mr. Minister. With this reform, we hope once again to work on the future of all of us.

Finally, a special thanks to the services, for the immense work, such as the translation and support, that they have provided in the last few weeks.

I would also like to thank the Chairman of the Committee on Finance. In these cases, the government could have submitted the draft laws a little faster, which would have given Parliament more space and more possibility to deal with everything in a good way. Nevertheless, we have found that this Parliament, thanks, among other things, to the Chairman of the Committee on Finance, has had reasonable resilience and flexibility to deal with all these drafts and proposals in the very short term in the committee and eventually put them to vote. This can also be said.

I also thank the opposition for the cooperation, because it has indeed made it possible for us to stand where we stand today.

Finally, colleague Calvo, I had to look strange a few times afterwards, because the accusations flew back and forth, just before Christmas. I hope that this period may lead to peaceful days between opposition and majority as well as with the majority and to pleasant end-of-year celebrations.

Thank you, Mrs Smaers.

The word is to Mr Van Biesen.

Mr. Speaker, first of all, I would like to join the last words of Mrs. Smaers, though not in a Christmas atmosphere but in a year-end atmosphere. I want to make one thing clear: we can only meet here today for the corporate tax reform thanks to the effort and willingness of all parliamentarians in the hemisphere. I would therefore like to repeat what Ms. Smaers said: I thank all members of Parliament, from any political group, that they have been willing to address the reform in this way in the House.

The way the discussion went was, in fact, du jamais vu in Parliament, or rarely seen. The discussion of such an important reform could have gone completely differently. As we always do, we could have taken the time to talk quietly with all the actors in the field. After those discussions, we could then update the reform where necessary or at least perfect it.

The Open Vld is extremely pleased with the corporate tax reform. Mr Piedboeuf referred to the important table of the National Bank stating that our country has the third highest rate of corporate tax in all Europe. We need to be competitive with our neighbors and with the rest of the world. Therefore, a fundamental reduction of tariffs was necessary.

What has not been discussed here today is the fact that the lowest rate is also taken on a much larger basis. Previously, the lowest rate was only 25 000 euros, now it is being expanded to 100 000 euros. The rate of 20% puts us behind in the peloton, thus on the better side of the tables in terms of competitive battle. The 20% is lower than in our surrounding countries and has thus become more competitive. This is the most important and fundamental reform that is being undertaken today.

The second major task we gave to the government two and a half years ago in this hemisphere was to reform this corporate tax, but to ensure that SMEs pay less and multinationals and large corporations pay more.

All the analyses show that there will indeed be a shift of 2 or 3 billion, 2 to 3 billion which SMEs will have to pay less and which the large companies and multinationals will have to cushion. This is an important given. The conditions for this reform, namely a shift in corporate tax, less for SMEs and more for large corporations and multinationals, that fairness process, that tax justice has been implemented with this reform. This is an important given.

We also suggested that the budget should be neutral. This reform took two years. During this period, significant measures have already been taken, which have already increased a very large part of the corporate tax. Just think of the reduced influence of the notional interest deduction, which many colleagues here said years ago was the greatest gift given to SMEs. I look especially at the sp.a-banks, where they said it was a gift. In the party program, we talked about a $12 billion gift to SMEs. Today, this notional interest deduction is no longer of interest to ⁇ . It is only a very low percentage, based on the OLO interest rate, which only exists for the portion that increases equity over that period. In other words, only an exceptionally small percentage will still use it.

This is no longer discussed. It is said that this gift now suddenly no longer exists, but eventually it has caused a sharp increase in the revenues of corporate tax. The Minister will be able to do that. It has already been introduced, and it has already brought numerous millions of euros into the State Treasury.

Against the plea of some that corporate tax should be budget-neutral today, I suggest that it should be budget-neutral over the entire period. Companies have already deposited billions more today. For us, in the future there may be a bit of tax reduction for companies. That will be the result of this corporate tax reform.

In other words, the companies have already made their contribution and they will be able to recover a bit thanks to this reform. It will be primarily SMEs and SMEs that will get the results.

Now to the hearings of yesterday.

I thought it was a missed opportunity, colleagues. I am, of course, very happy that the people of the UCM have come here. I also listened to them with all the attention, as I always listen. I can confidently say here that I am almost the only representative in this Parliament, ⁇ together with Mr Piedboeuf, of that organization. Therefore, we can expect to know many of their views.

The [...]

Are you a member of UNIZO? That is now the UCM. It is good that we are with a few.

That is right, because Parliament must be the representative of the people, and in other words, of everyone.

The [...]

We held a hearing with the UCM on a particular part, in which...

The [...]

I said: I thank everyone who took the hearing... When I thank everyone, it is also to those who took the initiative. I had already said that, Mrs. Kitir. I thank everyone who has taken care of this.

I thought it was just a missed opportunity that we could not have done this more thoroughly and spontaneously, a few weeks ago. Then we could have talked with other organizations, such as UNIZO, the VOKA and the VBO. Then we would have clearly heard that everyone is pleased with this reduction in the corporate tax. Then we would have clearly heard that every company in this country demands this.

The only problems that arise are some measures that we have had to introduce in order to ⁇ budget neutrality. Sometimes they have gone a little too far in that area.

There are three major points of criticism. We hope that they can be reviewed in the future, not in the totality, but in certain areas.

First, the increase from 36 000 to 45 000 euros. One speaks of indexing and an index jump that should also be there for business leaders. Business leaders must now get an index jump. They should not receive an increase now. More than an index jump. Over the next 10 years, they will have to make an index jump. The story of the index jump lies in between. The indexation is, of course, an indexation in terms of indexes. You also know, an index is a health index. Wages have not evolved in the same way in this country. The 36 000 euros, whatever the way it is calculated, it would be fair to index it as we suggested at a given moment and always index it in the future. A sum of 45 000 euros has now been chosen. I think there will be a number of talks next spring to see if that 45 000 euro really matches what really lives on the ground. We can still discuss that amount. This can be adjusted during the financial year. That is no problem.

Second, much worse is the introduction of the penalization. Sometimes a company is founded with an unpaid business manager. Why Why ? The purpose of the company is not to accommodate a commercial activity in it, but rather houses, apartments, a business building, the own company. There are always unpaid managers. In the future, they will have to pay 5 % over the margin of EUR 45 000 that they should have had as business leaders. That 5% will be raised to 10% in the future. I think this does not correspond to reality. I therefore call on the government to make an adjustment to this and to submit it to Parliament next spring.

A third important point with which we have a problem is that the capital reduction has been implemented. A capital reduction in a company is, of course, not taxed today, one has inserted his money there, but is prorrateed in the future against own capital. This means that if one has made a profit, this is re-qualified as a dividend and you pay 30% on it.

It is, of course, unacceptable that shareholders who put money into a company, that money – I mean clearly merely capital – should not get out of it without paying a moving fee. I do not understand that this could fail in the creation of the text. Therefore, I call for a clear step from the government, an adjustment in that area.

All these measures were taken within a budget neutral framework. It is therefore also good to refer to the position of the National Bank, which has confirmed that this whole reform is budget-neutral and, in addition, does not take into account returns. It is a very good decision of the Parliament to vote today on the corporate tax, because I am convinced, if tomorrow everyone in our country knows how the fork is right at stake, that the economic effects of this fundamental reduction of the rates will be visible fairly soon. I hope that the designers of this text will therefore be inspired to make changes in the sense of the three elements that I just cited, namely the position of the 45 000, the penalization and the capital reduction. I really hope that we can make progress in these areas.

Many colleagues have already mentioned the many good other measures. This is how I think of the investment withdrawal. Mr. Laaouej, it is true that it is limited to 2019, but if that measure proves to be very good, no one in Parliament will feel prevented from extending that measure to the next fiscal year. I invite you to do it yourself. Let us quietly look at the return effects of this measure. The return effect of the corporate tax reduction will be fundamentally high, which everyone who has some bond with companies knows. This will also generate a lot of money for the State Treasury, as is more common in the case of cuts.

We have made reductions several times. With liberals in governments, this happens slightly faster than in governments without liberals. The liberal as MR/Open Vld is still a very big as in this government and the idea of tariff cuts that bring more money to the State Treasury is once in our liberal genes. We are therefore firmly convinced that the reduction of the corporate tax will benefit the State Treasury.

For these reasons, our group will vote in favour. We are hoping for sufficient corrections in the spring.

Mr. Speaker, Mr. Minister, colleagues, today we are discussing a major reform, a fundamental reform of our corporate tax, a reform that is of social, economic and budgetary importance. Therefore, it is obviously a pity that the treatment has gone like this.

I hear the majority petitioners like to say that they are grateful to the opposition for its cooperation in obtaining the approval of this corporate tax reform, in which we have a number of fundamental concerns, however, before the end of the year. Nevertheless, I agree, also to you, Mr. Speaker, that the Parliament is being put to the test. We quickly expressed our objections to approving the proposed major reform — which I would like to emphasize — at a glance. This was also stated by members of the majority. I have noted it. Collega Van Biesen said he had never felt so little respect for his work as a member of parliament. Colleague Van Rompuy spoke about misprints for Parliament. I just heard colleague Van de Velde talk about a victory for Parliament. I really look at it differently.

If even the State Council, which is the Parliament’s fundamental partner in delivering good legislative work, concludes that the 30 days given to it are simply too short to be able to examine such a reform thoroughly, that it has not been able to conduct a thorough investigation and that it regrets that, then the question arises whether we as members of Parliament still take ourselves seriously enough.

If even for such an important reform – I just want to emphasize how important it is – we find the advice and our own discussion subordinate in order to be able to work quickly, then we must look in our own belly. We agreed as an opposition, because it is especially important for SMEs that the reform can start at the beginning of next year. However, this method is not susceptible to repetition, although this may have been said in the past. Per ⁇ , Mr. Speaker, it should be agreed in the Conference of Presidents that anything that has not been submitted to Parliament before the beginning of December will simply not be discussed before the end of the year. We must seriously think about that thought track, because the method followed does not work.

Mr. Vanvelthoven, I will return to this later today.

and fine. Thank you Mr. President.

In the context of the corporate tax reform, I would like to express another frustration.

Mr. Minister, you said nine months ago that the texts were finished. The texts of the Summer Agreement were also ready. I asked questions in the committee in September, as the chairman knows. You said then that you would rather want to discuss the draft at the time the draft is being discussed in Parliament. So you did not respond to my comments. I repeated my question in October. I received the same reaction from you. I repeated my question in November. Then you replicated – I quote: “I strongly advocate for the debate on the subject in the context of the very exhaustive debate that we will hold in the coming weeks following the reform of the corporate tax.” You added that, as you addressed me, “If you can find yourself in it, we can all deal with it more positively.” A very exhaustive debate for weeks... it didn’t come out of it.

The fact that you did not engage in the debate with Parliament during September, October or November, Mr. Minister, even if it was just over the main lines, is a missed opportunity. I have heard you say after all the discussion with the UCM whether or not she was invited – I will not go into it more deeply – that the first mail had already been sent in February and that there would have been contacts via mail in September or October. I found that there was indeed an explanation given to the VBO. I’ve noticed in recent months that tax offices gave paid lectures to their clients about corporate tax reform. Everyone was informed. But if a simple opposition parliamentary member interrogates you up to three times in the committee, this is not the time. I would like to speak to you, Mr. Minister. Do not do that anymore. If you feel that you need to inform the VBO, if you feel that tax offices need to be informed about it in order to write to their customers about it, please take the step to Parliament and start the discussion with us.

Mr. Speaker, I would like to say this too: not only is time now tight, which in itself is bad; the Parliament is no longer valued. This should concern all of us. I do not want to make a game of opposition against the majority. But if our institution no longer considers it important that it has time to discuss, if it no longer considers it important that the State Council has time to give a thorough opinion, then our democracy almost becomes one in which the government decides everything. That is a democracy that I absolutely do not want.

I go to the content.

What is important here is that there is a large support in our society to reform the corporate tax. This reform is based on a number of principles that have been discussed here. A first important principle, with which everyone agrees, is that we want to make our SMEs, the engine of our economy, pay less taxes, while the multinationals, the big ⁇ that today pay too little, have to pay more. This is an important tax shift. There is also a large consensus on a second important goal, namely the simplification of our system. The third principle, which I would like to address, is budget neutrality. It has already been discussed here, but you know that we put great questions on it.

If we talk about that shift in corporate tax, which means that we tax SMEs less and big companies more, it is still strange that yesterday we heard a key representative of SMEs by example – we can discuss it – explain that the proposed reform is not of interest to them. In fact, the UCM in Parliament has come to express its opinion on behalf of all the members it represents, stating that their members were not waiting for the proposed reform, while the VBO, the representative of the large companies, is ⁇ pleased with the present corporate tax reform.

Again, one can argue about the correctness of the examples, but if one puts those two facts side by side, one sees that those for whom the government says to reform are not satisfied, while those for whom it was said to pay more are satisfied. Logically, there is something wrong. Mr. Minister, I will go on to this immediately. I am convinced that the objective of this tax shift is not sufficiently achieved. This is also the reason why we cannot approve the tax reform.

We are primarily concerned with the following, and we have already talked about it many times. While new standards are being applied internationally, the fiscal context has completely changed and tax planning is being countered internationally, we see that in the bill proposing the reform of the corporate tax, international standards to prevent tax planning, about which we should make international agreements, turnover and exceptions, if possible, are inscribed as much as possible. I refer to the ATAD (Anti Tax Avoidance Directive). Someone later spoke about the National Bank. Well, according to the National Bank, the estimate of the budgetary impact of the corporate tax reform is indeed consistent with the European Commission’s estimate of revenue if there were no more profit shifts, which requires that ATAD be rigorously transposed into the tax legislation of all Member States. But that is not the case. Belgium is the exception. We are the country that ATAD makes very minimal or almost no revenue. So we undermined the income we budgeted.

While we see progress internationally, we see the opposite in the text. Some of the fiscal measures in the present reform again offer opportunities in our country in terms of tax planning. I will not go into it very deeply, but I would like to give a few examples. The reform of the DBI deduction simply offers new opportunities for financial planning. We would like to see the notional interest deduction completely abolished at this time of low interest rates, but it is now being reformed to make fiscal planning even better possible. The group contribution is also a measure that is very suitable for tax planning. In this case, profit can be pushed between companies without compensation.

In other words, the bill contains a number of measures that enable the tax planning of large companies.

I would like to take one example in this regard, which is really speaking. It is about the limitation of interest withdrawal. The ATAD Directive obliges the European Member States to introduce a restriction on the deductibility of interest. It is a good thing to want to impose the problem internationally.

In the present draft law, which has since become a bill, it is chosen to make use of a maximum of an exception. That exception is that these are loans concluded before 17 June 2016. Interests on those loans from before 17 June 2016 remain deductible. Colleagues, which means that those loans are excluded from the scope of the ATAD Directive and that companies that have made excessive interest payments in the past can therefore retain that excessive interest deduction. We now have the opportunity to deal with it for the future and for the past, but we do not.

The High Council of Finance issued a report on this in 2016. 123 companies have made excessive interest payments in the past in the framework of existing loans, all of which we argue that this should no longer be and in the future will no longer be possible. Those 123 companies have made those payments in the past and can continue to do so with the bill proposed by the current majority. In this way, they avoid an amount of 942 million euros in taxes annually in our country. This is what the current majority wants to maintain in the future.

That is the shame that is hidden in the bill. In large words, we want to address the big companies, but at the same time we are developing exceptions so that those companies can still avoid as much as possible. What we want to impose on the future, we dare not impose on the past.

That is the shame that is in many of the measures of this bill. That shame is reason enough for us not to approve the reform.

I hear Mr Van Biesen say that the National Bank has said that the reform is budget-neutral, but that is not correct at all. The National Bank did not say that. She pointed out many risks in the reform and ⁇ did not say that she is budget neutral. This also applies to the Court of Auditors and the European Commission.

I know that you would like to say that the reform is not budget neutral. You have also repeatedly said that it is not a problem that the reform costs money. The question is, of course, who will pay for it. The people on my right-hand side of the hemisphere say that the reform should be budget-neutral, but we all know that this will not be the case. With the approval of the present proposal, we give today an uncovered cheque to the government. An uncovered check means that at some point someone has to pay the invoice. We fear that the bill will have to be paid by the families, by the ordinary man in the street, and that is a second reason why we, given our experience with the first tax shift, cannot approve this reform that is not covered.

The last element is the simplification, but also that is not actually in it, Mr. Minister.

I have also given examples of this. A number of measures are being made more difficult for SMEs, so the government does not meet either. However, one of the objectives of the reform is simplification for companies.

We have submitted a number of amendments in the committee, with the intention of offering an alternative. That alternative would be that we would fully, rigorously, without exceptions, transpose the European anti-evasion directive and thus maximize international tax evasion. We have proposed to completely abolish the notional interest deduction and retain the DBI deduction for real, direct investments, thus not allowing deduction for expenses made purely to obtain tax-free income. This is also not accepted. We also requested that the group contribution scheme be temporarily removed from the proposal, so that we can calmly examine it and introduce a real fiscal consolidation. This was also rejected by the majority. It is a pity, because in this way the reform could have become budget neutral and fairer. We could have allowed the big companies to contribute more to the tax shift in the context of corporate tax, but the majority did not want to know.

Finally, I have decided not to submit the amendments we have submitted in the committee here.

I see that Mr Van de Velde is no longer here, because he would take this at heart. I also proposed yesterday to consider the transposition of another directive, the UBO Directive on access to the UBO register, before the end of this year. After all, it was planned that this would come into effect from 1 January 2018. That was in your design. The corporate tax is now out there. That remains in the design.

Given the high urgency, an important European directive in the context of tackling tax fraud, we have proposed to accept those three articles from your draft as an amendment to this corporate reform. These are three articles that were unanimously approved during the discussion of the draft in the Committee on Finance. These were also recommendations from the Panama Commission. I think there is therefore no problem that these three articles, expressed in the amendment we have submitted, are also accepted. Everyone agrees with this. It should be done before the end of the year.

This is one small signal in the framework of tackling international tax fraud. I think it would be good if Parliament approved this.

Dear friends, what a waste!

Both Ecolo and Green were demanding parties for a tax reform of the corporate tax.

We were demanding, indeed, we had said it several times in the long-standing tribune, a corporate tax reform that simplifies the system, which removes both expensive and unfair tax niches. We mean here the notional interests, which we are the only ones to have rejected in 2004, when they were put in place, since there was no condition of job creation for those who benefited from this measure, that it was not sufficiently targeted, that we identified already at the time its extremely costly character. Between 2004 and 2017, we abolished notional interests, but they will have cost the state budget tens of billions of euros, without having an impact on economic creation, job creation, the development of the endogenous economy, in the amount of the expenditure made.

We wanted a tax reform that favours self-employed and SMEs, that creates activity here, at home, in Belgium, of non-delocalizable employment, and all in a neutral budgetary framework. Because the contribution of companies, like other economic actors such as natural persons, is important for the financing of the state, for the financing of social security, because they benefit from the services rendered by the state, educational services, all the infrastructure that is paid by the state budget. We are not like Mr. Van Biesen, believing that the more we lower the tax rate, to the infinite, the more the taxes will rise. Minimum taxes are required, but this system needs to be corrected. We asked you, you did. And you did it in a catastrophic way. What a waste!

What have we seen in the last few days and, more generally, since July 27? First, the stubbornness of the majority. Last Thursday, we received in session two bricks that corresponded to the entire transposition of the Zomerakkoord, your famous Tomorrowland agreement. You wanted to impose on us the treatment, in a hurry, of all these measures, good and bad, in 72 hours.

We had explained that this was impossible and, as of Thursday 14, we had submitted a proposal to you. We were willing to deal with corporate tax measures in isolation, even with criticism. You then tried the force blow, but you lost. However, you would have been well inspired to listen to us faster. Your stubbornness is one of the reasons for this waste.

The second reason for such waste is the obvious division of the majority on these measures, as well as on other policies. I will not return to yesterday’s controversy with Mr Francken, although it is very serious in terms of respect for human rights, nor to the Energy Pact, even though it is indispensable and urgent in the perspective of an ecological transition of our economy and of safeguarding the planet for future generations. I just want to illustrate and denounce this bad theatre piece that the majority offered us this week.

Only CD&V supports the measure relating to securities accounts. The other coalition parties do not even hide their hopes that the Constitutional Court will break the text, if it is voted one day. Mr. Piedboeuf, you had requested a second reading to delay the implementation of the project. We were also ready to vote on this measure today. Only the Open Vld supports the provision aiming at the taxation of labour. The team counts the points. The prime minister goes on television platforms to try to reassure the public opinion, when he is not taking selfies in Paris or Tomorrowland. It is the N-VA that laughs in its corner and pulls the browns out of the fire. This “kibbel cabinet”, this government of division gives a pity image of our country.

The fourth characteristic is improvisation, especially in terms of the order of work. Thankfully, you have received a constructive proposal. Unfortunately, you had to repeat it constantly in order for you to catch it. I also think of the last-minute amendments that have arrived and the obligation to examine complex texts within timeframes, ⁇ a little more reasonable than those you initially imposed, but which in any case do not favor serious work. Finally, a second reading of this corporate tax reform was abandoned. However, it was fully justified in view of the complexity of the texts, as well as the importance of words and virgules in tax provisions – because the devil nestles in details. This was not possible.

There will be a second and a third round. You are already announcing a correctional law. Do not doubt, Mr. Minister of Finance, that many questions will be asked to verify compliance with the commitments, especially budgetary, that you have made. As demanded by others, clearly, precise and regular monitoring is necessary given the budgetary importance of the amounts concerned (5 billion euros) and the hypothetical nature of the compensatory measures you have imagined.

I repeat, I have repeatedly denounced it, that the calculations you have made and that the National Bank has validated, a little too lightly to my taste, are based on the 2015 figures of corporate tax, that is, the 2014 financial year. No serious private economic operator would base its economic forecasts on such ancient data. This is a way to hide the fiscal reality of your measures. We denounce it and we regret it.

Especially, what a waste in relationships with social interlocutors! What disregard you have shown towards a key representative economic operator: the Union of the Middle Class. We had to insist heavily that this interlocutor...

I would like to draw the attention of my colleagues and the Minister. This is proof that a file like this cannot be processed under conditions that make it impossible to conduct in-depth analysis. In the new arrangement that we are proposed to adopt, the comparison of the minimum remuneration of the manager will be made in the future not with the taxable income of the company, as is the case now, but with the tax outcome of the company, tax outcome that is defined in article 74 of the Executive Decree of the Code of Income Tax and which is obtained by subtractions operated on the taxable income.

This means that the term for comparing the minimum wage has changed. While today it is the taxable income of the company, tomorrow it will be the tax outcome of the company. This will obviously result in making it more difficult to access the reduced rate, because you have shortened the comparison term arising from the company's income. It is no longer the taxable income, but the taxable income. Did everyone see this?

This gives even more reason to the Union of the middle classes. This should then lead you to review all the calculations, because the tables you gave us are completely wrong. This completely changes the discussion. I would like to have clarifications as soon as possible and have a new presentation of the tables you have provided to us, taking into account what the corporate tax results are currently.

Mr. Laaouej, I thank you for supporting my proposition: obstination, division, improvisation, contempt. Disregard for key social partners. I would like to give you a brief reference to the Monday afternoon episode. You have been able to recreate a common front of the social partners of the FEB to the UNIZO, passing through the Union of the middle classes, the FGTB, the CSC and the liberal trade union against your taxation measure of 500 euros per month, 6,000 euros per year of work. It is a catastrophic measure in terms of unfair competition, loss of rights for workers, definition of social security, questioning of associative work.

The hearing took place under conditions that were not optimal but it was possible to take place. The reports are explicit. We hope that this part of the text is finally put aside. We will be there to fight it as soon as we return. What then can we say about the conditions of the hearing, this Thursday afternoon, of the Union of the middle classes? This topic has already been discussed several times by my colleagues in this general discussion. My colleague Vanden Burre will return there. We want to reaffirm, as environmentalists, the representation and expertise of the Union of the Middle Class on SMEs and self-employed in Wallonia and Brussels, and therefore throughout the country.

If this key interlocutor tells us that there is a problem in this minimum amount of 45,000 euros of manager’s remuneration for access to the reduced rate, it is that there is actually a problem! Many of these companies will not be able to access the reduced rate. If they write to you on October 26 to report this problem and you do not answer them, then there is a problem within Parliament. If they come to explain it here – ⁇ starting with an example – based on their expertise and knowledge of the field and that you do not react more, regardless of the government party – but especially the MR – there is an even bigger problem.

This file is a new illustration of the logic of this government in terms of social consultation: "Cause always, you care about me!" “You gave us your opinion, after we decide,” no matter the consequences. This is absolutely not the concept of environmentalists in terms of social consultation.

If, for many years – this is one of the characteristics of our country – governments have listened to the social partners, it is not to entrust them with the keys to the budget and legislation, but it is because they have the expertise to prevent the legislator from making the wrong decisions and it is also because once the decision is made, it is they who are on the ground to create economic activity and employment, who generate tax and who allow a State to function. You cannot indefinitely stumble on social concertation and consider as less than nothing those who are active in making our economy work while we are debating in Parliament. You take huge risks in terms of pensions, health care and, in this case, corporate tax. This is really one of the most damaging characteristics of this government.

We can share the fact of removing tax niches, reducing the nominal rate of corporate tax, especially for SMEs but far from the declared intentions, this government does not realize its ambitions. Your government is “do what I say, not what I do” and this file is a new illustration of the difference between triumphant communication and concrete acts far away from declared intentions.

What a missed opportunity! A successful corporate tax reform could have been a new momentum for our economy, Mr. Minister.

It is not just about creating a climate, it is necessary to take concrete and credible measures. We need to restore confidence, a budget balance and a re-balancing of contributions between the powerful actors, the big companies, and the actors more dependent on the economic context but much more anchored in our socio-economic territory.

It could have been a social progress if, beyond the measure of reduction of corporate tax for the first 100,000 euros of SME profits, you had not made sure that it was SMEs themselves, and young workers elsewhere, who were responsible for financing this reduction of tax.

In your budget tables, at the level of revenues that allow to partially offset the cost of this 5 billion euro reform, there is an amount of cruise speed of 177.3 million euros of sanctions against corporate leaders – this is the famous measure denounced by the UCM – and an amount of 97.2 million euros – the other measure denounced by the UCM in relation to capital reductions. This is a total of €270 million that will be borne by those whom you say will be the main beneficiaries of the measure. There is something that does not work. We have been explaining this for days, without reaction, without commitment to correct this measure.

Il y a moyen, et revenant sur d'autres mesures qui ne se justifient absolument pas d'un point de vue économique – notamment le passage à 100 % au lieu de 95 % de la déductibilité fiscale des revenus définitivement taxés –, les rest à la neutralité budgétaire théorique et laissant les opérateurs économiques concernés par ces RDT continuer à contribuer au budget plutôt que de leur faire un cadeau.

(...) You rightly emphasize social consultation, but is Green of the opinion that taxation should also be discussed there? Social consultation often involves wage conditions, labour law, social security. Taxation has never been the subject of social consultation. For example, you are in favor of a property tax. In your program there is a property tax of five billion. There is also the effect rate. Should we also present these things to the social partners? Will the mid-employment organizations, the employers’ associations, be involved in this? Should taxation be discussed?

That is new. Taxation has always been the privilege of the government and the Parliament. For example, the effect tax has never been submitted to mid-range organisations. Do you mean that if you presented them to the mid-range organizations those who would find them good or bad? I think you should be careful.

If you make taxation the subject of social consultation, you will be even further away from home, because it is often impossible to reach any consensus on that. At the beginning of the legislature I could read in your program that you are in favour of introducing a property tax of five billion. Do you think it should be submitted to the social partners?

This is a constant and common strategy of Mr. Bogaert and Van Rompuy when they are questioned about measures. I make a parenthesis: I know you don’t get very well but, nevertheless, you have a common strategy, that of diverting the shot by questioning us about our own measures.

I send you back a question. Because the effectentaks, I understand well, is a measure of the CD&V. I wonder if you agreed to it and with whom?

To answer your question, it is true that a distinction must be made between social security and wage policy that clearly holds to the tradition – a tradition that has good because it brings cohesion and social concertation – and other fiscal measures that should not go so far in terms of concertation. But we think, as environmentalists, that the participation of citizens, from the municipal level to the federal level, and the listening to the field interlocutors help to avoid mistakes.

In this case, the UCM hearing, for which we had to fight, having been alerted by the field actors, allowed to identify errors, voluntary or not, in the balance of your corporate tax reform. We denounce your blindness, the lack of listening and taking into account remarks that seem fully justified to us.

When the leading representative organization of SMEs and self-employed workers in Wallonia warns us that, based on the studies it has carried out and its knowledge of the field, the limit of €45,000 you have identified is too high, it is worth being heard. This limit will ensure that the majority of companies represented by the UCM will not have access to the discounted ISOC rate and will be financially sanctioned for this. Why don’t you correct your text? Why does the MR remain silent about this reality? This is the question I wanted to ask.

I was sorry for missed opportunities economically, socially and environmentally. Certainly, there are measures in terms of commercial cars but which are millimetric in view of the enormous challenge of their cost. You could have properly funded your tax reform by fundamentally revising the system of corporate cars.

In an undifferentiated manner, you propose an increase in the deductibility on investments, including for investments in carbon sectors, while we have taken, in various places, especially at the COP 21 in Paris, very clear commitments to decarbonize our economy. This is also a missed budget opportunity.

This reform is not as beneficial to SMEs as you are trying to make it believe. As I said, we support the measure to lower the nominal rate for SMEs because in fact, they largely escape the profits of the tax niches that have been created over time. They have only been at the margin of the benefit of the notional interest policy that has benefited mainly the large corporations, including those who, after gathering billions of profits, have disinvested our country leaving a social desert.

But, above all, the measures you have taken to limit the access to this tax reduction penalizes and penalizes mainly TPE, start-up SMEs, which have a limited turnover yet, or those who are in difficulty and that should instead just help to overcome a difficult conjunctual situation. There is therefore a mystification in claiming that this new corporate tax system will primarily help SMEs and that it is aimed at their benefit. Except, Mr. Piedboeuf, and there you still have work, to correct what must be and which has been clearly identified.

The question of who are the winners and who are the losers has been asked regularly, with an element that seemed to be consensual: it was necessary to correct the system of corporate tax contributions by making more contributions to the companies that have the most resources and generate the most profits, those that have taken advantage of the tax niches now challenged by the European Commission. We can welcome the work of Commissioner Vestager in relation to the excess profit ruling. For example, one can support the intentions of the OECD to have a common taxable base between the European states and if possible, tomorrow, common rates, this struggle against secret rulings that allow, in different states and unfortunately also in Belgium, companies to take advantage of tax systems that are far too advantageous.

We therefore regret that you have not been more severe with these companies, and more ambitious, despite what your budget tables are trying to make you believe. The way in which the majority plans to transpose into Belgian law, by this text, the ATAD directive against corporate tax evasion, which will ensure that taxes are paid where profits are realized, is far too little ambitious.

The directive, I repeat, proposes two paths for States: an ambitious path and a minimum path. You have consciously and voluntarily chosen the minimum path. You are trying to make us believe, through your budget tables, that it will produce maximum budget effects, estimated, in cruise speed, at 750 million euros. This does not resist any serious analysis.

Why be one of the only European states to have chosen to transpose this directive in a minimalist way? What logical explanation do you give to this? How do you justify the large gap between a minimum transposition and a maximum budgetary effect? This is absolutely not credible.

In the same way, why has the deductibility of the finally taxed income been raised to 100%, when it was fixed to 95%? This 5% difference may seem insignificant. However, the importance of the amounts deducted by some companies from the BEL 20 as part of this measure is well known, and the choice is not justified economically, nor in terms of employment increase, nor in terms of fair tax contribution. It is a gift you make.

What is the economic significance of tax consolidation? What will be its cost? Once again, we play with fireworks. It is estimated to cost us 500 million euros. Is it justified in terms of economic efficiency? Will it be controlled? You are budget adventurers, as I said last week, as part of budget analysis. And this without mentioning the possibilities to bypass the removal of notional interests, and the replacement of this removal by a deductibility of new own funds, by a fictitious decrease of own funds in 2017 and an increase in 2018, despite the rule of the average of the last five years.

My main and final argument, after the one concerning the fact that SMEs are not the real beneficiaries of your measure and that large companies will not actually be contributed, is the one concerning budgetary balance.

Mr. Chairman of the Finance Committee will probably remind me that the National Bank has validated your calculations. If I have a lot of respect for this institution, I still have a ability to read, analyze and criticize, which I find important in democracy.

We do not believe, Mr. Minister, in the budget balance of this reform. I would say even more: this is an intellectual deception.

I would like to ask you to take the time to rewrite the pictures.

I would like to refer to SMEs, as this is a very important issue. If the comparison term is no longer the taxable income of the company, but the tax result, it is necessary to know that the latter exists before the imputation of deductions. In other words, the tax result is necessarily always higher than the taxable income. However, today, the law compares the salary of the executive to the taxable income of the company to see if the right to the reduced rate is allowed or not.

In the bill that is submitted to us, the term of comparison is no longer taxable income; but the tax result that is always higher, by definition, than the taxable income since the latter is obtained by subtracting the result of the enterprise from a whole series of deductions. I am therefore certain that the tables you have provided us do not take into account the bill we are discussing here. As a result, simulations should be carried out quickly.

You’ll tell me that it’s hard to know what the difference is between a taxable income and a business profit before deduction. It is true. Nevertheless, you might take a number of standard cases considered reasonable to see whether or not there is a negative impact on SMEs.

In my view, your tables do not provide a sufficient basis for discussion and assessment due to legislative changes. In other words, you have submitted us tables that do not match the bill under consideration.

Mr. Minister, you tell me about the deduction of the manager’s income, but it is an accounting operation. Yes of course! Neither the tax result nor the taxable income of the company includes this remuneration. No one says that. You are told that there is a difference between taxable income and the result called "first operation" in the calculation of corporate tax. Between the two, there are deductions. So the taxable income is always lower than the "first operation" result. This means that you have lowered your first comparison term.

When I review the tables you provided to us, I find that your calculations relate to the pre-tax profit – therefore, the taxable profit. However, this is not what the bill speaks of, since it is interested in the outcome of the taxable period. This is understood depending on the definition contained in Article 74 of the Execution Decree of the Tax Code.

and yes.

Yes, you have changed it. If you take article 215 as it exists at the moment, it is written: "taxable income of the company". In your bill, it becomes: "result of the taxable period". This is not the same, Mr. Minister. Since the terms of comparison are different, the calculations are no longer the same.

This is not the way to calculate.

You will not agree. I therefore give the floor to Mr Gilkinet so that he concludes his speech.

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Mr. Van Biesen, Mr. Gilkinet will conclude. The Minister has just responded to Mr. Laaouej. It is good!

This is typically a discussion that should have taken place in good conditions in a committee in the framework of a first or second reading. I take advantage, at this point, to apologize to the majority in the House services and to thank the translators and services who have had to work this week under absolutely innumerable conditions to enable the vote of this text.

Mr. Van Biesen, do you mean something?

Mr. Gilkinet, it is I who gives the word! But I’m not sure it’s fun for everyone.

Mr. Frédéric, as President, you must give the word when people ask.

Is there a difference between the current and future ways of acting in taxation? The Minister answered clearly no. I want this to be very clearly stated in the report because it is very important for the accounting world.

Mr. Van Biesen, I think that everything that is said in this homicide is transcribed word to word. There is no need to insist on the subject.

Everyone has the text of the bill. Many of you have access to the internet, including the Fisconetplus website, where you can find the Code of Income Tax. I invite you to compare the current article 215 of the Income Tax Code, which speaks of "taxable income", to article 217, where it is about "resultat of the taxable period". It is not the same thing.

I told you to be careful. A word in taxation can have great implications. I didn’t say it by chance. I was talking about deductible dividends. I am talking about the reduced rate. You changed the notions. It is no longer the same. I would like to do the legal check, let you have time to compare well. You are referring to the “outcome of the taxable period”. You have removed the reference to the notion of "taxable income".

Mr. Speaker, I hear Mr. Minister say, “Nothing changes.” I hear Mr. Laaouej say, “It’s different.”

We have heard that too, Mr. Van Hees.

Mr. Speaker, if you allow me to continue without being cut off: I refer to the texts. In the new text, I see "equal or higher than the taxable income of the company" and in the old text, "equal or higher..."

( ... ) No, it is the opposite.

It is the opposite.

Have you finished, Mr. Van Hees?

I ask the Minister if there is a change.

This was the question that Mr. Leaouej had already asked. He has already answered.

No no no no! of calm.

and calm? You are not the one who finds yourself in your reading.

I ask the Minister if there is any difference between the articles.

We understood it. Is there any difference, Mr. Minister?

No, that is not my question! Sorry, but I can say what I want to say.

Yes, express yourself clearly.

I ask the Minister, if there is a difference, what causes the difference.

Change the word then.

But not . A result of a taxable period is not the taxable income. Between the two, there are deduction positions. Sorry, but this is the ABC of taxation. You have done a bad job. This is not acceptable. It must be recognized.

This will be the end of this exchange.

Obstinence, division, improvisation, contempt! A profit for SMEs that is not what you are advertising, a contribution from large companies that is not what you are advertising, and a budget result that is not there. This is a mathematical trick!

You remove some niches, but not all. You are creating new ones: RDTs, tax consolidation for companies. You finance your reform with virtual economies, those relating to notional interests.

It would have had to think much faster, when rates were higher, about the abolition of this device and its fundamental reform. And you are trying to make you believe – even to Mr. Van Rompuy, the chairman of the Finance Commission, guarantor of the budgetary orthodoxy of this state – that the result will be null, that the expenditure will be balanced with the new revenue.

This is absolutely unbelievable and I would be tempted to believe that this is the real agenda of this government or at least some components of this Parliament – Mr. Van Biesen also endorses my proposal. This is really problematic in the fiscal situation we know after we have contributed our fellow citizens in such a significant way, after questioning the means of investment of the federal state.

This is why, unfortunately, we will not be able to support a reform that we called our wishes.

Mr. Speaker, I perceive that your patience has limits and I will therefore endeavour to be synthetic in order not to exaggerate this debate that Mr. Speaker of the Commission hoped to conclude around 13:00. It is already a little late and we are not yet at the end. So I will try to go to the essential.

Five speakers are expected.

This moment was very much awaited for me. To be able to discuss a proposal for corporate tax reform, we have long sought it.

The CDH group, from the beginning of this legislature, deposited a text that I co-signed with Benoît Lutgen and Catherine Fonck. As far as I know, this is the only text of parliamentary origin attached to the discussion, which is a sign of our willingness to reform the corporate tax which we have seen, during the previous campaign in 2014, that it had reached its limits and that it had become unavailable.

Our tax reform that flowed into this bill was very clearly aimed at ending an increasingly obvious anomaly, namely that gap between revenues from corporate tax lower than the amount of deductions granted to these same companies. There was therefore an increasingly flagrant divergence between the nominal rate and the rate actually paid by the companies. We considered that this complexity damaged the legibility of the tax system, our competitiveness, and that it induced discrimination between companies.

The proposal we had submitted was aimed at lowering the tax rate to reach the European averages because we have always considered that our taxation should be integrated into a European approach. It could no longer be conceivable to suffer this disability compared to the European average rate. We also proposed, in the text attached to the one we are examining, to reduce the SME tax rate to 20% up to 150 000 euros of taxable income. Our proposal also included arrangements to stimulate investment and innovation in companies. Finally, we proposed to eliminate the deduction for venture capital: notional interest.

It is to say that we were not very far from what is currently under examination. The philosophy that encouraged us – and always encourages us –, which underlined this abolition of the mechanism of notional interests and this reduction of the corporate tax rate, consisted in making taxation more legible and fair, in removing tax niches and in avoiding the multiplication of particular mechanisms of which only the most knowledgeable or best advised can fully benefit.

It is necessary to stop adding layers to the tax lasagna. This creates distortions, threshold effects, aubaine effects that encourage taxpayers to operate financial and fiscal shopping strategies.

Efficiency also comes through the transparency of the rule. The facial rate should be close to the actual rate.

Through this proposed tax reform, we also intended to put an end to a mechanism that had proven to be extremely costly, that of notional interests. At the time of the presentation of this device – which we owe, except for my mistake, to the then Minister of Finance, Didier Reynders – we were announced a cost of the order of 400 to 500 million euros. Over time, the cost has climbed to several billion euros, 6 billion at most, a sign that there was a failure to hold a budget commitment, to integrate and to ensure the necessary budget neutrality. I say it because it is on the basis of this experience that, from the beginning, we say – in the speech, we join, but in reality, it is something else – that a fiscal reform must now impose itself with a real budget neutrality.

Another element that we really wanted to change structurally is the fact that notional interests benefited mainly large companies. Studies have shown this repeatedly, including studies by the National Bank. The tax advantage of notional interest benefits small and medium-sized enterprises only at a rate of slightly more than 20 % of the total cost. Other studies, including those conducted by the University of Namur, also showed that given the geographical distribution of the tax advantage of notional interests, it was well understood that this advantage was essentially located in the head of large enterprises and not in the head of small and medium-sized enterprises.

But we know that it is small and medium-sized enterprises that make the socio-economic fabric of our Regions, especially in the Walloon Region. Since they did not benefit from the majority of these notional interests, it was important to change the system to establish a more favorable mechanism for job creation. Ultimately, notional interests also had the characteristic of being very expensive, without actually creating jobs, even though they had other advantages or goals such as strengthening the capitalization of companies.

Therefore, we want to analyze the reform you propose in line with these two criteria. Is there a real budget neutrality? Is there a preferential advantage for small and medium-sized enterprises?

We were determined to work for a corporate tax reform. We were encouraged to do so later by reports that were added to our analysis. These have shown that the international environment is now prompting to change the system of tax niches. The implementation of the BEPS Action Plan and the proposals of the European Commission have questioned the relevance of preferential schemes or tax niches. It was necessary to examine new scenarios, better adapted. For Belgium, this meant re-examining the relevance of a strategy where tax competitiveness is based on preferential schemes rather than on a comparatively interesting nominal rate. This was stated by the Supreme Finance Council in 2016.

Our impatience to move to act was therefore great, beyond the proposals and reform intentions that Mr. Minister had expressed. We wanted to review a text to vote on it. This is why, at no time, we have used dilatory manoeuvres to delay the parliamentary process. We have not obstructed the government’s draft and its translation into a bill. We even agreed, no later than yesterday, to vote for the emergency, in order not to further penalize the economic world.

I must give you a confidence: I was even willing, on a personal basis, to plead with my colleagues that we vote on a corporate tax reform while still in the opposition. However, frankly, after analyzing the text you submitted to the table of Parliament, after hearing the various speakers, and after analyzing the documents, we cannot reasonably approve your corporate tax reform.

Why Why ? For two or even three reasons. The first is the so-called budget neutrality. Hearing the positions taken within the majority, we feel well that this neutrality is of variable geometry. If you look at the main sources of financing for your reform, you can only conceive doubts about the reliability of your estimates. The removal or adjustment of notional interests would account for more than 40% of the total funding for the reform. This is an amount of two billion out of the five that represent the volume of the reform. Honestly, the assumptions you are working on are justified by certain elements. But cuddled cat is afraid of cold water. Following experience at the time of the establishment of notional interests, we are suspicious of forecasts based on interest rate assumptions. At least we are very concerned.

The second element that leads to being extremely cautious is the transposition of the ATAD Directive. We have already talked a lot about it. Based on a macro estimate, you estimate that this could bring about 1.2 billion euros. You eventually agreed to anticipate somewhat the implementation of this Directive. Unfortunately, on this directive, as on many others, you have a somewhat frigid approach, not accepting to integrate it fully, to apply it fully but, on the contrary, a little at the card with escapes that have already been the subject of discussion. I don’t want to go back, but this is another missed opportunity.

The third most important element on which your funding is based is the return of the basket, to resume the formula, a return that you estimate at more than 500 million euros. There is also something that is not guaranteed since all the bodies that have been brought to review your proposals have considered either that certain assumptions were plausible – this is the case of the National Bank – or, on the contrary, that there were really great concerns. I think in particular of the Court of Auditors who, in its report, showed a number of difficulties: the fact that the data on which your calculations are based were outdated, the fact that the changes in the behavior of companies could hardly be integrated, the fact that the analysis carried out by the SPF Finance is a so-called static and non-dynamic analysis. All this has led the Court of Auditors to be ⁇ dubious. The European Commission itself considered that there was a risk factor in the evolution of our public finances.

There is therefore a real concern with regard to budget neutrality, especially since, I must tell you, Mr. Minister, the discussions in committees have not reassured me about your willingness to ensure a real monitoring of this device. You have been questioned several times. Mr. Laaouej has done it again recently, and so far, we have never heard a somewhat reliable, somewhat concrete response on the monitoring mechanism that you are going to set up, I hope, to ensure the follow-up of this corporate tax reform. We await your response with impatience. So far, in any case, we have not heard anything about this. The experience we have experienced with the tax shift, honestly, does not encourage us to trust since, as we know, at the moment, the tax shift is not fully financed and therefore, the risk is real that this new tax reform will not be financed either unless you manage to establish a mechanism that effectively guarantees that the goals will be achieved. At this point, I consider that is not the case.

The second criterion leading us to consider that the account is not there and that this reform can not be approved is this problem of winners and losers. We have repeatedly asked you who could benefit from this reform. You answered that it was difficult to give an answer on this subject and that it depended on the profile of the companies, etc.

Honestly, this answer is not satisfactory. One cannot imagine for a second that the SPF Finance could not produce real, numerical, proven analysis of the gains that the different categories of enterprises can draw from such a reform. You were not able to demonstrate to us that SMEs could actually benefit from this reform.

Since the demonstration has not been made, we are forced to consider that the reform will not bring what SMEs expected. To be convinced of this, it is enough to read the report of the National Bank, to which you regularly refer. On this issue, it is quite explicit and it adheres to a philosophy that you cannot clearly express, but it stipulates that “the preferential treatment of SMEs must be reevaluated.”

I totally disagree with the formulation. So far, in particular on the basis of the notional interest mechanism, I consider that there is no preferential treatment for SMEs, but it would be necessary. This development, which is desirable in our view, the National Bank wants to counter it, because it considers that it must be extremely cautious in relation to the incentive given to SMEs. Therefore, there is an underlying preference for large companies, of which it is known that they already benefit to the maximum from the current scheme.

Beyond this discrimination between large companies and small and medium-sized enterprises, it must be noted that yesterday, at the hearing of the Union of the Middle Class, we had the demonstration that discrimination was well present compared to small and medium-sized enterprises wallon and Brussels. It is not to enter into a community conflict for pleasure but to find, on the basis of the figures provided by the UCM and which have not been contested, that effectively, the average income of entrepreneurs is not equivalent in the North and South of the country and that there is an objective difference; the average at the level of the calculations of the UCM establishing for business leaders at 35 000 euros per year. It is known that the numbers are higher in the north of the country, which led UNIZO not to challenge the increase of this minimum threshold.

But there is clearly a discrimination that the French-speaking economic fabric will suffer. I truly regret that this statement could not have been heard by all the majority parties, and in particular, by the Franco-speaking party supposed to represent the interests of the Wallon and Brussels companies. On the contrary, it was observed that a number of mechanisms were re-established. In particular, I think of the increase in the deduction of RDTs. Mechanisms are set up to facilitate tax optimization in the head of large companies. There is therefore really a imbalance that seems to us unacceptable and that leads me to consider that the gift you present to SMEs is actually a poisoned gift; the UCM has not been mistaken.

Then, Mr. Minister, dear colleagues, there is one last element that frankly puts us in the impossibility of approving this reform: the method used. You will all agree to consider that within this parliamentary instance, the method was chaotic, rocambolesque. I do not have a long parliamentary experience but I have the impression that the oldest of us have rarely experienced a parliamentary process of this type. The timing was reduced to the strict minimum simply because the government delayed in filing its texts. Amendments to its own texts have been submitted by the government. Subsequent texts were also announced to correct the submitted texts. In the end, the texts were taken back by the heads of the group, to wonder whether they read the texts they assume since they were not even in the commission to present them, while they were supposed to be the bearers of this bill.

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Madame Fonck, it is Mr Dispa who has the word.

In any case, it is clear that the group leaders will pass for the fathers carrying this reform and everything it contains, including, for example, the limitation of the possibilities of tax deduction for provisions for risks and charges. This is one example among others that will impact small and medium-sized enterprises, which may not yet be fully aware of it but will eventually discover it when transparency comes to light.

Objectively, the drafting of the text was chaotic and rocambolesque. And then, frankly, how not to denounce the lack of dialogue. I will not use the term “concertation” again since the Chairman of the Finance Committee noted that social concertation cannot, as such, be applied to a tax reform.

But, in the absence of social concertation, at least dialogue mechanisms would have had to be established. By the way, Mr. Minister of Finance, you said yourself, on the occasion of the preamble of your intervention aimed at defending the reform in commission, that what was most important was the climate of confidence. You stated that in economic terms, what is important is to create a climate of trust and to provide guarantees, in particular, in terms of legal certainty and tax stability, to companies.

Honestly, on Thursday afternoon, we did not have the feeling that there was a great climate of trust between the Minister of Finance and an actor as important as the UCM.

Now you explain to us that emails have been exchanged, that the reform was on the website of your office. This is not what I call a dialogue.

I would not want to repeat myself, but when we were in the Finance Committee to hear the UCM, the chairman of the House paid tribute to Philippe Maystadt. He highlighted, as I did on the day of his death, the listening qualities and decision-making abilities of this statesman. He mentioned the title of a book of interviews he published, Listen and Then Decide. This is a method of governance that seems to me intelligent and corresponds quite well to the traditions of our country. Even if, in tax matters, there is no social consultation, an advance dialogue with field actors is always preferable.

I said here to the prime minister, that I was a little hurt, which I am sorry for, that I had the feeling that he was doing the opposite. Deciding and then listening is what we have had the bright demonstration of this week, since you have decided on a reform by refusing to change it. And then in extremis, you agreed to listen to the UCM, but without hearing it and without giving a real follow-up to the problems raised. Listen and then decide: you do the opposite.

Just recently, Mr. Piedboeuf said that he would be listening to the UCM.

It is good, and I am delighted. However, I honestly think that this dialogue should have been initiated earlier, so that misunderstandings could have been dissipated. We might have been able here, not to reach a consensus, but to convince us of our ability to respond, through a corporate tax reform, to the problems of the economic actors of this country, in particular the representatives of SMEs.

On the question of the negotiations, the Minister had asked for the word, but this is no longer the case. However, Mr. Piotrich asks for the word.

Mr. Speaker, I just wanted to react to Mr. Dispa’s comments. We are constantly on the field, whether with the UCM, the Chamber of Commerce, associations, etc. Thro ⁇ the year, we receive messages and comments. We are constantly listening.

As for the reform of the ISOC, and I said it recently, while the information has been spreading for months and months, here is a dozen days ago that we received an email from the UCM, which drew our attention only on three aspects. I am sorry to repeat myself, but there have been talks and we will continue them.

When Mr. Nyst defended an option and tables by abstaining in particular from referring to the 50/50 rule, this caused misunderstandings. I told him that we were called to see each other again and we will see each other again. Mr. Minister has already proposed to come to the province of Luxembourg to the meeting of the financial sector and the Chamber of Commerce to explain the reform. We will therefore develop all the necessary popularization, because enormous aspects of this reform need to be clarified. If measures are not understood, we will take our pilgrimage rod for this purpose.

There has been a continuous monitoring. It is obvious that it will be organized, both on the budgetary level and on the effectiveness of the provisions. When we have delivered this analysis – we have talked about it with colleague Van Biesen a few moments ago – if it appears that adjustments are needed, we will do them. But in order to be able to adjust, we must first begin by undertaking reforms. We set foot in the door and therefore launched reforms. It is fundamental.

I will give the floor to Mr. Dispa. In the meantime, the President is back.

Finally, Mr. President and Vice-President.

The words of Mr. Piedboeuf are the perfect illustration of what I said. I proposed a method inspired by Mr. Philippe Maystadt: listen and then decide. You do exactly the opposite! You decide and then listen. “We’ll talk,” you said.

This is a method that seems to me not good and which now makes it difficult for us to assess the real impact of the proposed measures, in particular on Walloon SMEs. If you have heard correctly, a dialogue or listening began yesterday afternoon. The Chairman of the UCM did not speak on his own behalf but on behalf of the entrepreneurs he represents: he expressed an insistent request to make a correction to some aspects of the reform.

This is why an amendment has been filed, co-signed by several parties who have heard this message and who are willing to correct, in the interest of Walloon and Brussels SMEs, the problem of the minimum wage, the contribution of 10% in case of remuneration less than 36 000 euros, the double penalty you impose on them and also the pre-count for the reduction of capital. These are reasonable requests expressed. An amendment will be submitted to vote.

If you have heard about the UCM, you can only vote for it. You have not signed the amendment, but you can still vote on it. If you do not, you will have demonstrated that this reform is a missed appointment for Brussels and Walloon SMEs.

That is why, on our part, we will not vote for your text. We will abstain because we are convinced that the status quo is not a good solution. There needs to be a good reform on this point and there we can join. But not this reform, not with its cost, not with the effect it will have to the detriment of SMEs.

Mr. Speaker, I would like to add one point that I find essential to what my colleague Georges Gilkinet has already explained in detail and in a very relevant way.

There are a number of factors that raise concerns about this legislation. I do not come back to what Georges Gilkinet has brilliantly demonstrated about the overall financing of the reform. I would like to delay a moment on the goal that, for us, is missing in this text. This is a real regret. We would have liked to participate in a major reform of taxation, corporate taxation with a special attention, a special encouragement for SMEs and self-employed people.

As I said earlier, two categories of SMEs should be encouraged, according to the ecologist vision. These are the smallest structures, of 1 to 4 people, which today represent between 80 and 85% of the 900,000 SMEs in Belgium. These are very fragile structures of up to four people, for which a difference of 1,000 euros or 500 euros, an imprecision on a gross salary, on an equation can make a difference in cash but also a difference in the sustainability of business and activity. For us, this category is the one that should be targeted as a priority by this type of measure. This is what I was concerned about in the discussion we had yesterday with UCM officials.

For an EPO that employs one or two people, your baker, your butcher, your gardener, do you think it’s easy to move from 35,000 to 45,000 euros a year in salary? Is this done in a flick of fingers? There are order books to fill out, an economic context. All this is ⁇ difficult, especially for those companies that employ a small number of employees. However, this is the vast majority of the entrepreneurial structure of this country: Flanders, Brussels, Wallonia.

There may be some differences in pay, I do not disagree, but it’s the same structure.

The second target audience that is for us fundamental in an entrepreneurial policy and encouraging entrepreneurship is that of start-ups: those and those who start their business, who, by definition, are alone, or maybe two or three but that is usually not more.

All policies, and ⁇ tax policy, need to be directed at the public. Think here that those who start this type of business do so for tax reasons! Think that those who embark on entrepreneurship do so to pay themselves maybe even a few thousand euros a month, but this is often not the case. I think – and many colleagues know the business world well – that this is not the case. The UCM also told us that they often pay less. We even have salaries that sometimes range from 500 to 1,000 euros gross per month because they want to invest the most in their business. With a measure that increases the threshold from 35 000 to 45 000 euros, they are likely to be disadvantaged.

For us, it’s going against everything we have in terms of political view of such audiences and encouraging them taxally. I repeat again what has been said by my group many times, for many years: a tax reform is absolutely necessary in this country, it is a measure of tax justice in favor of SMEs, TPE and self-employed compared to a whole series of tax deductions, but it is absolutely necessary that these measures target in priority small structures and especially start-ups, those and those who start into an entrepreneurial project. At that level, apart from everything that has already been explained by my colleague Georges Gilkinet, we have huge fears! We regret it.

We will be able to support articles that go towards a decrease, towards a tax incentive, but not the articles on compensatory measures in the current state of debate, quite incomplete in our view.

I remember the words of my colleagues Piedboeuf and Van Biesen who said: “We really want to revise these conditions, if necessary, and continue the debate.”

I hope we can take you to the floor in twelve months, when we make the evaluation. We will see if it is effective for those companies we are targeting, in a vision of encouraging entrepreneurship and business development in our regions. We have the biggest fears. We believe that this is not the case. But let’s evaluate it together in twelve months. And most importantly, let’s change the rules if we notice that they are not effective.

Mr. Speaker, Mr. Minister, dear colleagues, I will not return to the political conditions that led to the consideration of this bill. I will stop at its content. I will do more technical analysis, but I will also appreciate the political orientations underlying them and the political choices that have been made at the expense of certain sectors of activity.

If some measures contained in the bill (since it has been transformed) deserve to be supported, such as the reduction of the nominal rate – which was also the subject of a proposal from my group – others cannot be validly supported.

First, as regards the nominal rate of corporate tax, the termination of the complementary crisis contribution. My group is in favor of this reduction of the nominal rate, which will take place in two phases. In the long run, the total nominal rate will therefore be raised to 25% for large companies. The reduced rate of 100,000 euros will be 20%. But as already mentioned, although the budgetary impact of such a reform is not negligible (over €4,766 million), the willingness to reduce the rate of taxation of corporate profits is a necessary measure, subject to verifying its budget neutrality.

As regards the reduced rate for small and medium-sized enterprises, which will be set at 20% on the first tranche of €100,000, the complementary crisis contribution will also be removed. These are two favorable measures.

However, we also find that the conditions for access to this 20% reduced rate have been changed. In order to benefit from this rate, small and medium-sized enterprises will have to grant a minimum remuneration to their managers of at least €45,000, instead of the €36,000 currently granted by tax legislation. This measure is highly critical. In this regard, I would like to point out two elements of criticism.

First, according to the information communicated during the hearing of representatives of the UCM in the Finance Committee, the median remuneration of business executives in the Brussels Region and the Walloon Region is 30 540 euros per year. The average salary is slightly less than 35,000 euros per year. The amount of €36,000 fixed by the legislation in force to benefit from the reduced interest rate corresponds therefore more to the reality of the figures than the amount of €45,000 retained in your reform. This information allows me to highlight an important point: the UCM represents ⁇ 100 000 independent workers and ⁇ 32 000 companies located in Brussels and Wallonia. Therefore, I find it quite distracted that some members of the majority, wanting to be close to the world of SMEs, dare to call the main French-speaking employer organization communist. I know that some in this assembly may be flattered by it, but it seems to me that it is totally indecent.

Second, it can also be denied that many small and medium-sized enterprises are or will be going through financial and economic difficulties. They will therefore not be able to pay a remuneration of this size, the minimum of which is set at 45 000 euros. These companies will not be able to claim the reduced tax rate. In other words, in addition to going through financial difficulties, they will be taxed even harder if they make a profit. That is why my group submitted an amendment aiming to maintain – even not to change – the current remuneration threshold of €36,000 per year, so that SMEs can benefit from the reduced tax rate under the conditions currently in force.

The majority therefore intends to introduce a separate social contribution at the expense of companies that do not allocate a minimum remuneration of €45,000 to their business executives. The rate of this separate contribution will be fixed at 5% of the taxable base during the first phase. It will be raised to 10% in the second phase of the reform.

Although this new contribution or tax is not applicable to small and medium-sized enterprises during the first four taxable periods from their date of establishment, it cannot be denied that many companies are or will one day experience a difficult situation. The latter cannot therefore consider, at a certain point in their existence, to pay a minimum remuneration of 45 000 euros to their leaders. Therefore, there was no need to retain such a separate amount of contribution.

Let me take an example. A small company has a taxable base of €60,000 for the tax year 2021 (revenue 2020). It does not grant remuneration to its leader for various reasons and agrees to honor the penalty for lack of remuneration. This company, in addition to being taxed on its profits at the height of 25%, since it cannot claim to the reduced rate of 20%, will also be imposed a separate contribution in the amount of 4 500 euros.

In other words, regardless of numbered examples and other simulations, you will not disagree, Mr. Minister, that companies and especially SMEs will inevitably be damaged by your reform, will be penalized in terms of economic activity.

If Mr Piedboeuf is listening, he can only support the amendment that aims to remove this separate contribution that has no serious economic objective, on the contrary, since it is a penalization of the middle classes.

Allow me to extend a moment on the reform carried out by the government in terms of capital reduction. The current regime provides that where the social capital is not constituted solely by liberated capital, commonly referred to as "good capital", a capital reduction may be carried out solely on the liberated capital. There was therefore a freedom of choice in the imputation of the capital reduction. In other words, previously, the total capital reduction could be attributed to the capital actually paid without being taxed.

The proposed reform provides that, from now on, the freedom of choice in the imputation of the capital reduction will no longer be allowed. In addition, the company must compute the capital reduction on some of its taxed reserves. A capital reduction will therefore result in the award of a dividend taxed at the rate of 30%. This change will necessarily affect companies that have incorporated reserves to the capital, but also companies that have distributed reserves.

My party does not, in principle, oppose a reform relating to capital reduction, a technique often used by tax advisors to optimize the assets of their clients. However, we make some reservations regarding the short-term impact on business behavior. Indeed, it is not impossible to see a number of companies make a capital reduction again this year in order to take advantage of the current advantageous tax regime. If so, the expected revenue benefit of the reform will obviously not be confirmed.

I continue to analyze the new measures and stop on increasing the deduction of the final taxed income from 95% to 100%. The government has therefore decided to grant a total deduction of the income definitively taxed. To the extent necessary, I recall that this deduction of permanently taxed income or RDT tends to avoid double taxation or the distribution of dividends and that, under certain conditions, of course, bonuses of acquisition or liquidation between several related companies.

The amount of the deduction currently in force is fixed by the Income Tax Code at 95% before withdrawal of the furniture pre-count. The remaining 5 percent actually corresponds to flat-rate charges. According to the information communicated by the SPF Finances, the modification of the regime of the deduction of RDTs, will generate a loss of tax revenues of some 80 million euros and this, only for the year 2018. In our sense, this is an additional tax advantage that is given to large companies but especially to holding companies.

We are therefore submitting an amendment aimed at ⁇ ining the system of deduction of the income definitively taxed at 95% because such a measure will therefore result in the maintenance of a recipe, a recipe that would be much more usefully used to benefit SMEs, within the framework of the amendments we have submitted, to make choices. Between privileging holding companies or supporting the activity of SMEs in Wallonia and Brussels as well as in the whole country, it is still better to support those who create jobs in our Regions than to taxally support holding companies. This is why the MP is failing in relation to a whole portion of its electorate.

I will now stop on the abolition of the taxation at the rate of 0.4% of the surplus value on exempt shares of large companies referred to in Article 217, 3° of the Code of Income Tax. Starting from the 2019 tax year, large companies will no longer have to pay the 0.4% tax on the surplus value on shares they make. This change represents another tax gift to very large companies of almost €60 million in cruise speed. In our view, it is in no way justified given the reduction of the nominal rate of the corporate tax of large companies, to 25%. Therefore, we are submitting an amendment aimed at ⁇ ining this marginal tax rate.

With regard to the reform of notional interests, of course, you are taking a first step.

It was indeed time to reconsider this mechanism, which at one time was justified, but which no longer corresponds to the current economic context. Nevertheless, you maintain a deduction for venture capital, but it will only apply to additional venture capital compared to the average of previous years. This is the so-called notional interest in incremental capital. We are committed to reforming this fiscal niche. However, it would have been more logical to remove it purely and simply, because there is no point in ⁇ ining it. This would have been a greater budget promise, as it no longer corresponds to the current economic situation.

Finally, I would like to point out the balance of the budget. Unfortunately, I fear that the history of the collapse of revenue will be confirmed, without properly compensated. Sure, the National Bank has given a favourable opinion on the fiscal neutrality of the reform, although it is very cautious in its conclusions. Moreover, it is not the only body that has analyzed the budgetary implications of the reform, as other stakeholders have expressed clear reservations. This is ⁇ evident from the hearing of the representative of the European Commission, who expressed some of his concerns. I think thus of his considerations about the increase in advance payments. The European Commission has noted that some simulations are based on obsolete recipes. She cites the notional interest reform recipe in this regard and adds that her estimates remain cautious and still relatively high with regard to tax revenues. In short, she says there is a risk that the transaction will not be budgetarily neutral.

Similarly, the Court of Auditors found that it did not have the information necessary to assess the fiscal neutrality of your reform. It was able to estimate the revenue resulting from the gradual decrease in the deduction of notional interest, which, I recall, should – in the long run – generate more than 2.3 billion euros of tax revenues, or ⁇ half of the total cost of the reform.

However, it is important to remember that the calculations of the SPF Finance are based on figures from the fiscal year 2015, income generated in 2014, that is, three years ago. I do not think that, in this case, these data are reliable for evaluating budgetary compensation.

I will conclude by citing the Court of Auditors’ opinion on funding the corporate tax reform: “SPF Finance has established its calculation rating in an unchanged environment, without taking into account the effects of return or changes in business behavior.”

We already know that the tax shift tax reform is far from being compensated on a budgetary level. I am afraid that with this reform, other budget holes will be announced.

I therefore believe that this operation, if it fulfils some praiseable objectives, nevertheless presents approximations likely to weigh heavily on the future of public finances. I consider that there was a need to deepen the corporate tax reform by removing further fiscal niches, which was not the will of the majority. As a result, we will not be able to support the project in the current state.

Ladies and gentlemen, this is really a great story. We started with a Summer Agreement, concluded in Tomorrowland, though my colleague already said yesterday that the lake looked like Rimpelrock. After the summer agreement, the autumn flip came. I think it’s going to be a winter deal, but it’s a winter deal. Indeed, only the corporate tax reform lies here as a Christmas present on the table on this second day of winter. The question is what the Spring Agreement will mean. Will the remaining items, such as the value tax and the non-taxable surplus earnings of 500 euros, still be there? Of course, that remains an open question.

I have the impression that the government was a little jealous of Vivaldi, who also had his four seasons. The government also wanted a new agreement, at least a negotiated deal, for each time of the year. Although I am absolutely not a fan of classical music, I have to say that Vivaldi’s composition “The Four Seasons” just sounds a little better than the four seasons of the government because in the latter there are a lot of false notes.

I come to my point.

We started with a bill of approximately 1,400 pages that was almost impossible to ⁇ . Today we have arrived at a bill, signed by the leaders of the four political groups, but yesterday no one was seen in the Finance Committee. I also feel sorry for the members of the majority who had to ignore this. There was no explanation because the signatories were not present. The Minister was able to answer the questions.

So, it is the corporate tax reform that is now under way. This reform is very important and we fully support it. There was even an agreement, beyond the boundaries of opposition and majority, that this reform should come.

There are two key aspects related to a corporate tax reform. First, she must be honest. Small or large, everyone needs to be treated the same way. There should be no exceptions and no major differences. Second, such a major reform as it is announced here must be accompanied by tax simplification. In that regard, however, we are absolutely not heroic. I am not convinced that both aspects, fairness and simplification, come fully to their right. This may have a lot to do with the way in which the bill was eventually adopted.

Mr. Minister, you would have better consulted in advance and given the Commissioners the opportunity to conduct such discussions, even if only on the basis of provisional texts. It would have been nice if you had involved Parliament in your contacts with the social partners, such as UNIZO, the VBO and others.

This is also very typical, Mr. Minister, because you have never been a member of Parliament. Ministers who have previously served in Parliament tend to be more inclined to involve members of Parliament, especially not the majority, in such legislation. It ⁇ ’t have been a bad thing if we had discussed it all together in advance.

Mr. Speaker, the Minister may not have been a member of Parliament, he does a great job. The only thing I really like is that we are holding this kind of debate, because some MPs will never become ministers.

This may be true of both of us, colleague Van de Velde. I do not pretend to be a minister, far from.

Anyway, I can only make that determination. So it might not have been so bad if Parliament had been involved and we could have conducted a deeper debate. Dear colleague Van de Velde, you declare that we have had a thorough debate here. It was nocturnal debates and some things could have been a little more thorough.

For example, colleague Laaouej must today ask questions on the basis of which the minimum benefits will be calculated, as the terminology used in the two texts differs. Then you can argue that you mean the same thing, but a tax reduction and a tax deduction are not the same, nor are tax evasion and tax evasion the same. When we talk about taxation, it is about nuances, which we know too well. So it is not bad at all to look at it thoroughly and I also want a clear answer to the question whether the calculation in the literal interpretation of the text does not involve a change.

This is, of course, the aim of the second reading. Fortunately, the poor secretaries of the Finance Committee were still assisted by secretaries of other committees, but even in this situation they can absolutely not guarantee that everything goes smoothly and the reports are perfectly in order. Furthermore, they would be able to make the legal corrections that might have been necessary. But legal corrections have not been considered at all, because there were no proposals around them.

Yesterday there was then the hearing with UCM. I am not discussing whether or not there were contacts and in what way. The cabinet sent emails to UCM. I also admit that the calculations that were proposed to us do not contain all the nuances. That is true.

We have received a large number of figure examples from you, for which I thank you. However, these were figs after Easter. It would have been much more interesting if you had provided us with the elaborate calculations and examples at the beginning of the discussion. You could then have used numerical data and examples to support your claim that the reform is in the favour of SMEs. Given the limited time, we could not verify this.

Yesterday, after the hearing, it became very clear that even that reform becomes a community problem. The increase of the minimum allowance from 36 000 to 45 000 – or the application of the 50/50 rule, if it works better – is not problematic for Flemish SMEs, but for Walloon and Brussels SMEs. Thus, to say that we do not have community problems here is not correct. There is indeed a community problem in this area.

It is criticized that the UCM would not have responded. The observation of many accountants was, when the texts were not yet definitive, that the managers of affiliated companies had to be paid a fee of 45 000 euros each time, which was a problem especially on the Flemish side. Fortunately, this has been placed at 75 000 euros and I am very satisfied with that solution. The increase of the minimum allowance from 36 000 to 45 000 euros even colleague Van Biesen was a bit on the high side. It is true that the amount has not been indexed for several years. But if one had made that calculation, one might have come out on a lower amount.

You say that with that minimum remuneration you counter the association-making. There is also nothing wrong with this. But we must realize that in this way people are deterred from entering a company and that others have already entered a company and are in that situation. I absolutely disagree with the assertion that one enters a Bvba or any other form of company only for tax reasons. I have my concerns with that. I therefore expect that 45 000 euros will probably be too high for some.

What I have even more trouble with than with that new threshold, because the problem of affiliated companies has already been largely solved, is the penalization. I would find it fairer if you simply said that those who do not exceed the minimum know where they are and must pay the higher rate; but that those who do not exceed the threshold or respect the distribution of 50 %/50 % will receive the lower rate. I think that for those who make the choice to pay the higher rate there should not be another separate attack. It is now in place and I find that especially regrettable.

I think the UCM’s reactions have much to do with the way this government has communicated. This is indeed a tax reform. A reform is a shift. That ultimately means: no tax reduction, unless it may not be financed.

This is a debate that can be carried out for hours. Do you know when we will know if it is funded? In June 2019, when the accounts will be there. Then we will be able to say whether everything was definitively financed or not. But that will not be a problem for this government, because then, of course, we are in full election mode and it will pass silently whether it was financed or not.

In terms of communication, however, many small and medium-sized enterprises – since it was a reform for SMEs – expected that they would have to pay much less. Now it turns out that there are indeed SMEs that have to pay less, but there are also SMEs that feel absolutely nothing about it. After all, it is not only because the nominal rate goes down that they get so much profit from it, as there are also the flanking or compensatory measures to bear the costs. The positive measures that benefit mainly SMEs, for example in terms of innovation and research, have less impact on small enterprises, while the negative compensatory measures of the reform tend to have a slightly greater effect. Since there have been such high expectations from SMEs about tax cuts, the reform will still be a cold shower for some. Globally, approximately 50 % of SMEs will move forward, while others will step down and others will continue to step down. Is all this wrong? No, I have not said that, but there must be honest communication to the citizens.

Another measure is the investment deduction, which is increased to 20 %. That is ⁇ positive, but it has long been known that that measure would come. As a result, investments have seriously decreased in recent months as everyone is waiting for January 1, 2018 to carry out their investment. As a result, investments are now somewhat stalled and we can understandably wait until January 1, 2018.

Another measure in the proposal, which I wonder if it will not cause problems in the future, is the story of capital reduction. Until today, a capital reduction that was implemented could be done tax-free. From now on it will no longer be tax-free. In some cases, 30% of taxes will be paid. The same story applies here too. Just as investments are postponed, we now notice and point out to the accountants at this moment that anyone who can profit from it is engaged in capital cuts. The new notional interest withdrawal scheme now enables companies to quickly implement a capital reduction and ensure that that same capital returns to the company the following year. In this way, they get an increase in their capital which they enjoy notional interest deduction.

Mr. Minister, I do not know to what extent your services will conduct checks in this manner. The question is also whether they have violated the law at all. Capital reductions are currently tax-free. If they are implemented now, that is no problem. The fact that someone increases their capital in January 2018 cannot be opposed. After all, this is exactly what we want, namely that companies hold their capital in their hands and have a good foundation. This, of course, includes the story of the notional interest deduction. I know that the notional interest deduction is taken into account over a five-year period. However, the question is whether there will be no shifts.

It is also a pity that we have not been given more time for this reform. If we had more time and could sit together with all social partners, accountants and taxists, we could have made more adjustments or simplified the legislation, which now sometimes is too complex. We could have done something beautiful. Unfortunately, that time did not exist.

I wish I had a promise from you. You have already announced that you would like to reform the personal tax before the end of this legislature. For me, this is absolutely no problem, because it is a second reform that needs to be implemented urgently. The personal tax must be simpler and fairer and there is a lot of work to be done in that area, because in the last fifty years – it’s even longer since the personal tax was thoroughly reformed – there have only been charges added, so it would be a very nice exercise. It would be nice if you take steps in this area that they are put in consultation with the members of Parliament. This path can be started in the new year.

Dear colleagues, I wish everyone a very happy Christmas party. I address these wishes to everyone: all services, including in particular the translators and secretaries, the employees of the opposition and the majority, and the employees of the cabinet, who have also been silent in recent days. I would like to thank everyone, from all sides, for the work done.

First of all, I regret the procedure. We are facing a profound change in corporate tax that would have required time and reflection, which should have left time for the State Council’s opinion and the place for numerous hearings and discussion of each measure to figure out its implications.

The government came to the last minute with this reform, which demonstrates a mixture of contempt for Parliament and amateurism. I don’t know what weighs the most in the balance, but ⁇ , the amateurism compared to the blockage it caused on the part of the opposition.

In the second half, the procedure dissolved. I notice a rather incredible aspect: it is the extraordinary inventiveness existing in this chamber to short-circuit the Parliament’s Rules, since a bill has miraculously become a bill. I would like to congratulate the authors of this bill, M. Verherstraeten, Clarinval and Dewael. Congratulations for putting in one evening a bill that fundamentally reforms the corporate tax! I am quite impressed, dear colleagues.

A draft law, which was distributed to us last night in the Finance Committee, will be voted in a few moments in the plenary session!

I did not know that it was possible to deviate the Rules to such a point in order to arrive at such accomplishments. I don’t know if the democratic debate wins a lot in this type of configurations, but in any case, we see the exploit. I did not think it was possible. Even the Rules of Procedure obviously do not have much value in this Parliament.

In my opinion, advertising is a lie. We have always been mirrored that a corporate tax reform would be, on the one hand, a reduction in the tax rate. He is right there. And on the other hand, an eradication of the tax niches of which our taxation has been overwhelmed for so many years. What is observed? We are far away. The risk is primarily budgetary. We are promised budget neutrality, but what is it really about? I recall, however, that in 2005, when voting on notional interests, Minister Didier Reynders had said that it would cost half a billion euros but that it would be budgetally neutral. It is known that it cost up to six billion depending on the years. Here, it is not half a billion that should be budgetally neutral, but five billion! The bet is ten times higher at the start. So imagine if we have the same budget departure as with notional interests, how much we will be in financial difficulties and how much more this will justify the austerity policies conducted by this government or its like.

The risk is obviously that half is financed by a notional interest reform but in the meantime, these have melted due to the falling interest rates. So, almost everyone has doubts about this budget neutrality.

This is the case with the Court of Auditors. This is the case for the European Commission and most of the experts on the issue. Then the government felt compelled to call the National Bank to the rescue, which I call the “government propaganda agency,” to say that this budget neutrality is assured.

The National Bank report says a lot. He says a lot of good about this corporate tax reform. This is not surprising because it obviously corresponds to his ideology. What the report does not say, however, is that budget neutrality is guaranteed. If there is one thing that is not found in the report, it is this!

Other instances are very clear. The FEB, of which I have already been able to say how much it determined the policy of this government, says that, ultimately, it is not important if budget neutrality is not assured. The editor-in-chief of Trends, he, wrote: “Let’s be realistic, the corporate tax reform is not budget-neutral, not even in a dream. The wish of Deputy Prime Minister Alexander De Croo (Open Vld) – “For me, this reform can cost money to the state” – will become reality. And this is also a good thing, because a budget-neutral operation would have little practical scope. “Whoever thinks that multinational companies will largely finance the reduction of the ISOC rate still believes St. Nicholas.”

Finally, Bart De Wever, the chairman of the Minister of Finance’s party, himself stated – in one of the Trends – “the corporate tax reform is a reduction in taxes. Whoever says ‘tax cuts’ obviously says ‘absence of fiscal neutrality’, by definition.”

There is another counter-truth, that tax niches are disappearing. I think, as for me, there are even those that are expanding, those that benefit just the multinationals. RDTs go from 95 percent to 100 percent. It wasn’t in the initial project but the FEB told the government: “Say, coconut, we want 100% and not 95%!”

by 100% FEB is served. It has a 100% RDT deduction. The same applies to value added on shares. The deduction is extended to 100%. In addition, they are offered tax consolidation that is likely to be a new tax Frankenstein after notional interests. There are some deductions that are removed but these are essentially measures that benefited SMEs such as the investment reserve, the deduction for additional personnel. Finally, these fiscal niches are largely ⁇ ined.

So we come to a third contradiction. The reform is aimed primarily at SMEs. The UCM stated: “The ISOC reform as presented is unbearable for SMEs.” it is worth it to be treated as “Communist Class Union” by one of our majority colleagues. Tax niches are only reviewed on the margins and those that are reviewed are those that concern SMEs.

As for the rate, it is interesting. First, the reduced interest rate is less revised downward than the full interest rate since it moves from 25% to 20%, which is a 20% decrease while the full interest rate moves from 34% to 25%, which is a 26%. For SMEs, a decrease of 20 percent. For companies paying the full interest rate, 26%. What does that mean in Euros? Unfortunately, this is something that the Minister of Finance has not addressed. There was no detailed calculation. What are the consequences of lower interest rates? You give a total amount, but you do not differentiate between reduced and full interest rate. What is the reduction of the reduced interest rate from 25 to 20 percent in billions of euros? This means virtually nothing. This means that there are no billions of euros. To find out, it is enough to look at the inventory of tax expenses. What do we see? That the current reduced rate represents a tax expense, thus a budget loss of €222 million, for a reduced rate that will be about 10% less than the full rate. If 222 million euros are needed for a 10% reduction of the interest rate, between 100 and 150 million euros will be needed for the proposed 5% reduction.

Finally, the reduction represents, on the one hand, €100-150 million for SMEs who benefit from the reduced rate, and almost €5 billion for all companies, mostly large companies. This is the real difference in rates, not to mention the tax niches. That’s 100 million for SMEs benefiting from the reduced rate, and almost 5 billion for large companies. This is a fact that the Minister, of course, refused to say.

Especially since the real problem for SMEs is not the rate of corporate tax, but to not be in deficit and to ⁇ profits. To pay corporate taxes, you first have to make profits, and many SMEs have trouble doing so.

Other disadvantages for SMEs include the disappearance of the exemption for SMEs, such as the investment reserve or the exemption for additional personnel. This is strange on the part of a majority who says “Jobs! The Jobs! work!” throughout the day. What tax deduction does it eliminate? The only one that is precisely focused on the number of jobs created. There is only one, and that is the one that the government chooses to eliminate. This is incredible hypocrisy!

Some measures are primarily beneficial to larger companies, such as equity gains, whose immunization is widespread, except for additional conditions. These are the RDT conditions. Who will be affected by them? The majority are SMEs. In terms of share value niches, the advantage is extended for large companies and the advantage for SMEs is reduced. It is exemplary. Only the treatment of this niche already says a lot.

There is the minimum wage - I will not return to the controversy - and capital cuts that also discontent the UCM.

A fourth false truth is that this reform is necessary for competitiveness. I have just explained that, for SMEs in particular, but even for any company, the problem is first to make a profit before knowing how much it will be taxed. I do not think it is essential to know this rate in terms of competitiveness.

Above all, there is the danger of a spiral down, the government doing fiscal “trumpism”. It also does so on other matters, such as the environment, weapons, etc. “Trumpism” is hard to pronounce. (Brouhaha) by

I would like to mention a study by the International Confederation of Free Trade Unions (CISL), entitled The Butter and the Money of Butter. How multinational companies escape tax redistribution. “If corporate tax cuts in the OECD and other countries continue in the future, tax rates will be close to zero by the middle of the century.” When I said this in the committee, our colleague Van de Velde intervened to signal me his approval: the corporate tax rate will approach zero by the middle of the century. For him, this is a good news.

Mr. President, I would like to tell Mr. Van Hees for a moment that he might have had to listen to what I just said.

Mr Van Hees, the reduction of corporate tax is an exogenous phenomenon driven by internal competition between states and at the same time by e-commerce. If you want to put your head in the sand, you need to do so.

I think that this government today is adjusting its tactics and strategy in a very adequate way so as to exempt as much corporate tax as possible. There are two elements, a market phenomenon and a social phenomenon. The social phenomenon involves saving as many burdens as possible. At the same time, the effective market situation must be taken into account. Keep on paying taxes; that is your plan. But in five or ten years, we will examine the market again and find that it is driven on a completely different basis. I said that, not that I am pleased that the corporate tax is going down.

I am naturally someone who does not see taxing as a fun business. At the same time, I think that one should consider saving taxes as much as possible, taking into account a good market situation. That is what happened now.

Mr. Van de Velde, we know your theory. When I said that according to this trade union forecast, the corporate tax rate in the middle of the century would be 0%, you said that you thought so too. For you, it is quite interesting to make the tax burden bear by the population rather than by companies. This is what happens when corporate taxes are reduced. Who will bear the burden? It is the population.

We need to remember where we come from. At the end of the 1970s, the corporate tax rate was 48%, excluding a solidarity tax of 4.5%, which a large part of the companies were required to pay. This was a corporate tax rate of 52.5%. Then we went to 45%, to 43%, to 41%, to 39%, and then to 34% in 2002. Now we anticipate 29.58% in 2018 and 25% in 2020. This means that over four decades, there is a division by two of the corporate tax rate. And this is just the facial rate. In addition, niches will play to reduce the actual corporate tax rate.

This is a discrimination against persons subject to natural persons tax. We will go, for the corporate tax rate, from 20 to 25 percent; 25 percent is where the tax payments of the corporate tax start, which goes up to 50 percent.

The evidence is that you are afraid that still a portion of natural persons pass into society. This fear shows, however, that there is a discrimination between individuals subject to personal tax and those subject to corporate tax. The OECD observes that there has been a transfer of tax burdens from companies to households for some time. The OECD is not a communist institution.

The [...]

I know . Some people think the UCM is communist. I understand that this government and that majority, who support big ⁇ and don’t care much about SMEs, can assimilate this to communism.

What is increasing as a result of this government’s policy? The rate of VAT on electricity, for example. This increases from 6% to 21%. However, if we refer to the electoral promises, especially the MR, we should never touch the VAT on electricity. So, apparently, some taxes can increase and others decrease. Those that decline are those that benefit the big companies. The ones that are increasing are those that are applied to the population.

Of course there are studies. The National Bank cited a study that a lower interest rate would have a negative impact. It is quite interesting to know the source of this study that was published in Empirical Economics. When one “crack” a little, one realizes that it is, in fact, a working paper of the National Bank itself.

As far as I am concerned, I have a study from Oxfam Netherlands that shows that there is no link between tax rate and competitiveness. This study is based on a comparison between different countries. By relying on a graph, it shows that there is no link between the two.

Ultimately, the corporate tax reform is simply a transfer of more labor to capital, as was the case with the index jump.

Among the lies, or rather the counter-truths – let us be careful – about this reform, there is the basket. Mr. Deseyn, who is not here for the moment, said in a committee that companies would pay a minimum of 7.5% tax. Was it a deliberate lie on his part or was it the expression of his ignorance? I do not know. But when I questioned the minister, he seemed a little upset and he tried to “nourish the fish” by saying that a normal business would pay a minimum of 7.5 percent. In my opinion, a normal company is not a multinational company. This clearly means that many will be multinational companies who will continue to pay very little or even zero euros of tax since apart from notional interests, this is only deduction delays.

Pretending that companies will pay at least 7.5% is, ultimately, a manifest false truth. Many will continue to pay 0% tax. Belgium will always be a tax haven for multinationals.

Furthermore, the PTB undertook a calculation from a sample of the fifty companies that benefited in 2016 of the largest tax deductions. It shows that they paid 1% tax last year. We developed a simulation based on the basket, which adds 0.7% tax. Their tax rate will therefore be increased to 1.7%. We are far from 7.5 percent.

Other factors will reduce the impact of the basket. First, companies will obviously arrange to be able to deduct the same year and have to postpone as little as possible from one year to another. Finally taxed income will then be deductible at 100% instead of 95%. Therefore, their delay will be less frequent. Above all, tax consolidation will allow multinational companies to compensate for the losses of one subsidiary with the profits of another. This will, of course, result in much fewer reports of losses. This means that the amounts submitted to the basket will decrease.

Regarding the ultimately taxed income, I have already indicated that it was a requirement of the FEB. I will not return therefore.

As I said, notional interests are an important part of budgetary compensation. Therefore, it is ⁇ dangerous to use it, while it is half based on a single measure. I consider that notional interests should be completely abolished, because those who want to maintain them, in this case in an embryonic form, invoke their need for own funds. But this is about rewriting history, since they were not created for this purpose, but rather to find a solution to the disappearance of the tax regime of the coordination centers – condemned by the European Union. By the way, if they really served to strengthen own funds, one would then have to ask why the final taxed income is put at 100%, since they promote a reduction of own funds by encouraging the distribution of dividends.

Secret committees remain obscure. Why does this government abolish taxes on secret commissions? These are companies that pay black workers to increase sales. They therefore do not pay ONSS or professional pre-count on the worker’s salary. They are exempt from VAT and ISOC on profits. There are a lot of taxes they avoid. It was logical that there was a substantial contribution on these secret commissions, but the government abolished this tax on the secret commissions.

In the committee, the Minister of Finance also talked to us about the measures of mouth-mouth. For example, provisions for risks and charges and accelerated amortization are removed. These measures do not have a long-term budgetary impact, but they have one between 2018 and 2020. One can discuss the well-foundedness of these tax provisions that allow to deduct provisions for risks and charges and accelerated amortizations but this is not easy because there are pro and contra. We could have had a substantial debate on this, but there was no debate. It was short-circuited by a budgetary objective. The Minister well explained to us in the committee that since some measures of tax compensation do not directly reach their full effects in the first years – only in 2020 – it was necessary to find mouth-to-mouth measures. For a temporary budgetary effect, measures are taken that will have an indefinite fiscal impact. This is the way this government works, which shows amateurism.

There are also professional pre-account exemptions. This is a bit complicated to understand because some are in the ISOC version and others are not. There are professional pre-account exemptions for research and development for undergraduates, which are found in the text that is submitted to us and there are professional pre-account exemptions on teamwork in the building sector, which are not found in the ISOC reform.

We try to understand the logic. Is it because the second measure is a relic of the tax shift that it was not included in the reform? It is still that with the dispensation of the professional pre-count, we are dealing with what I have called the “little brother” of notional interests, that is, a measure which seems anodine at first but which grows and which causes more and more massacres in the public finances since, today, even before the application of these measures, there is already a loss of 3 billion.

On the very principle, with these exemptions from professional pre-count, the employer draws from the gross wage of the worker the amount of professional pre-count that he must pay to the tax. But instead of paying everything to the tax, what does he do? He keeps a portion for himself and an increasingly important portion because some exemptions account for 80% of the employee’s occupational pre-count. If different sources of dispense are added, the 100% can be exceeded.

Normally, it is illegal but it happens very often that 100% is exceeded because it is well known that in this area, fraud is numerous and checks are rare.

Only with regard to the discharge of professional prepayment on teamwork in the building sector, this will amount to 400 million by 2020. So far, this measure represents 3 billion euros on all professional pre-account exemptions.

We asked the minister whether those 400 million euros, which appear to be a remnant of the tax shift, are integrated into the government’s multiannual budget planning. He answered us with the affirmative. When looking at the general report of the 2018 Budget (Table 21, p. 46) it is observed that in the government’s multiannual plan, this measure, representing 400 million less in the state budget, is not there.

Is this a flagrant counter-truth? What about this, Mr. Minister of Finance? These $400 million offered to employers are not included in the multiannual budget plan! In commission, the minister reassured us by saying that they were included in the base.

We do not know what this base is. So is there a "secret" base that is not in the general budget statement? That’s the question I’m asking myself: the budget is distributed to parliamentarians and there’s a secret base of which we don’t know the holders and enders and the numbers. That is quite worrying!

Dear colleagues, we will not vote in favour of this reform and I will sum up a few reasons as a conclusion.

First, because this reform will not be budgetarily neutral. It will cost billions of euros and it will be the people who will have to compensate for the shortage to earn. Second, because the tax niches for multinationals are not entirely eradicated from our tax legislation. Third, because this reform is not carried out for the benefit of SMEs but of large companies. Fourth, because the population will have to bear an additional tax burden, which will be added in the coming years to the austerity that this government has already imposed on us since 2014. And fifth, because the FEB thanks the government for this new gift. She also invited the minister to a lunch to talk about it and have the premiere of this project, which only arrived very late in the House. The BJP is ahead of the MPs.

Mr. Speaker, Mr. Minister, Ladies and Gentlemen, allow me to be surprised. The MR and other government parties are constantly communicating about the need to encourage personal initiatives, the dynamism of entrepreneurs – especially young people – to create activity and wealth. But in reality, nothing changes!

To discourage the initiatives, this government has done like its predecessors. In Belgium, it is discouraging to take future-looking initiatives, believing that success is disturbing. Thus, SMEs, TPEs are in the collimator.

How can one seriously require that a transition into a company takes into account a minimum income of €45,000 in the head of an executive? It will be difficult in Wallonia and Brussels. Return to reality! Given the tax pressure, few are SME and TPE executives who can count on a personal income of €45,000. Stop taking entrepreneurs for fraudsters in the soul! They want to work and create jobs. They are interested, and the whole population as well.

Transitioning into a company is not a form of tax fraud, but a way of protecting the private property of entrepreneurs who take risks. Have you forgotten that transitioning into a company is sometimes indispensable in order to be able to access public procurement or financing? And, on the level of democracy, the People’s Party regrets the retroactivity of new taxes. You kill all the corporate strategies. By taxing capital reductions, you immediately punctuate pre-accounts that should have been paid much later. In short, you punctuate and then, we will see well. Undoubtedly, until the next wreck to crush companies and initiatives.

And let’s not talk about the effect of your new measures on the image of Belgium! Who can still trust a country where the canvas of companies is changed with a disengagement that creates insecurity? As too often, your intentions are good but, in practice, they disappoint. For these reasons, I will abstain from voting on this bill on corporate tax reform.