Corporate Tax · Luxembourg Lionel Noguera & Anne Selbert, Bonn & Schmitt 85 Malta Dr. Donald Vella...

Contributing Editor: William WatsonPublished by Global Legal Group

Corporate Tax

Third Edition

CONTENTS

Preface William Watson, Slaughter and May

Angola Tiago Marreiros Moreira & Manuel Simões de Carvalho,

Vieira de Almeida & Associados 1

Argentina Ariadna Laura Artopoulos, M. & M. Bomchil 9

Belgium Philippe Malherbe & Isabelle Richelle,

Liedekerke Wolters Waelbroeck Kirkpatrick 13

Brazil José Luis Ribeiro Brazuna & Ciro César Soriano de Oliveira,

BRATAX – Brazuna, Ruschmann e Soriano Sociedade de Advogados 22

Cyprus George Economides & Constantinos Markou,

E & G Economides LLC – Advocates and Legal Consultants 36

Finland Kai Holkeri, Dittmar & Indrenius 44

Germany Ernst-Thomas Kraft & Martin T. Mohr,

Hengeler Mueller Partnerschaft von Rechtsanwälten mbB 50

Ghana Eric Mensah, Sam Okudzeto & Associates 60

Greece Tom Kyriakopoulos, Machas & Partners Law Firm 64

Ireland John Gulliver & Robert Henson, Mason Hayes & Curran 74

Ivory Coast Dr. Raymond Ika Any-Gbayere, AnyRay & Partners 79

Luxembourg Lionel Noguera & Anne Selbert, Bonn & Schmitt 85

Malta Dr. Donald Vella & Dr. Mark Galea Salomone, Camilleri Preziosi 93

Mexico Arturo Pérez-Robles, Ortiz, Sainz y Erreguerena, S.C. 103

Mozambique Tiago Marreiros Moreira & Frederico Antas,

Vieira de Almeida & Associados 112

Netherlands Wouter Vosse & Servaas van Dooren, Hamelink & Van den Tooren N.V. 119

Peru Rocío Liu, Miranda & Amado Abogados – Taxand Peru 125

Poland Piotr Karwat, Chadbourne & Parke LLP 133

Russia Maxim Alekseyev, Elena Novikova & Sergey Artemiev, ALRUD Law Firm 141

Singapore Kay Kheng Tan & Shao Tong Tan, WongPartnership LLP 151

South Africa Alan Keep & Mogola Makola, Bowman Gilfillan Inc. 160

Spain Miguel Ángel Sánchez, Javier Gazulla & Juan Garicano,

Hogan Lovells International LLP 168

Ukraine Natalya Ulyanova & Oleg Derlyuk, ICF Legal Service 183

United Kingdom Zoe Andrews & William Watson, Slaughter and May 191

USA Christian E. Kimball & JoonBeom Pae, Jenner & Block LLP 202

Venezuela Alberto I. Benshimol B. & Humberto Romero-Muci,

D’Empaire Reyna Abogados 211

GLI - Corporate Tax Third Edition 13 www.globallegalinsights.com

BelgiumPhilippe Malherbe & Isabelle Richelle

Liedekerke Wolters Waelbroeck Kirkpatrick

Overview of corporate tax work

As in many countries, 2014 has seen many tax changes aimed mostly at pursuing actions against combatting fraud and abuse and increasing revenue. An important part of the work was to inform clients about those changes. The Sixth State Reform – leading to more competences granted to the Regions and Communities with increased needs in revenue – was adopted in 2013. The Federal Authorities have implemented most of its tax aspects during 2014. Those changes, however, mainly affect individual taxpayers; corporate tax remains a federal tax. It is now up to the Regions to make use of their new competencies in the field of taxation. All three Regions are at the moment working on a reform of real estate taxation, concerning mainly the tax basis for individuals’ taxation and incentives in the acquisition and renovation of private dwellings. The Federal State retains principle jurisdiction and should soon pass a Bill which will tax individuals on income obtained through “legal constructions” such as foreign trusts and favoured holding companies (the so-called “Cayman Tax”), but also create new incentives in the creation and support of SMEs. In our previous review, we highlighted how, increasingly, European tax law is influencing corporate taxation. The reviewed period is confirming that trend. No new case was decided by the ECJ concerning Belgium corporate taxation; however some new cases have been referred by Belgian jurisdictions which are of interest for companies and their shareholders. Outbound dividendsIn recent years, the ECJ has issued a series of decisions dealing with the taxation of “outbound dividends”: basically, the Source State cannot levy a withholding tax on dividends paid to non-resident corporate taxpayers which appears to be a final tax burden on the dividends when the domestic system ensures that dividends paid to resident corporate taxpayers are not finally taxed or taxed at a lower rate, in situations where there is no possibility for the non-resident shareholder to obtain a refund of the withholding tax or a tax credit in its State of Residence. The case Commission v. Belgium addresses the situation of dividends and interest distributed by a company established in Belgium to both Belgian resident and EU resident corporate shareholders. It appears that the withholding tax is a final tax burden for non-resident investment companies, while resident investment companies may get a credit or a refund of that withholding tax.1 In the same line, the EU Commission is now challenging the Belgian legislation under the free movement of capital provisions, considering as discriminatory the situation where an investment company established in another EU Member State or within the EEA is


Liedekerke Wolters Waelbroeck Kirkpatrick Belgium

subject to payment of a withholding tax on interest payable on unsecured debt, whereas an investment company established in Belgium benefits from an exemption from that tax. It also challenges the situation where the interest payable on debts backed by Belgian securities is subject to payment of withholding tax when the securities are deposited or registered in an account in a financial institution established in another EU Member State or an EEA State, whereas that interest is exempt from withholding tax when the securities are deposited or registered in an account in a financial institution in Belgium.2 Discrimination and obstacles to taxation of capital income does not only result from withholding taxation. An interesting case has recently been referred to the ECJ3 concerning compatibility with the Directive concerning indirect taxes on the raising of capital and with the EU freedoms of the Belgian tax on undertakings for collective investment. One of the questions relates to the possibility for a Member State to unilaterally modify the criterion on the basis of which a tax is imposed, “in order to replace a personal criterion for taxation, based on the domicile of the taxpayer and laid down in international tax law, with an alleged criterion of actual connection, which is not laid down in international tax law, account being taken of the fact that in order to establish its fiscal sovereignty the Member State adopts a specific penalty as regards foreign operators only”.Fairness taxA so-called “fairness tax” has been introduced with effect as from tax year 2014; the tax claims to levy some tax on economic profit that has been sheltered from corporate income tax, by deduction of notional interest (NID) or of previous losses carried forward (LCF). The tax is levied at 5.15% on a basis equal to the excess of the gross dividends distributed for the period over the final taxable basis of the company multiplied by the following fraction:

Previous taxed reserves (until and including tax year 2014) are exempt.The fairness tax does not apply to SMEs as defined by the ITC. The tax is criticised for its complexity and, more importantly, for its potential non-compliance with EU law. In 2015, the Belgian Constitutional Court, seized by a petition for annulment, referred4 to the ECJ questions on the conformity of the tax with the EU freedoms and the Parent-Subsidiary Directive.5 Parent-Subsidiary DirectiveIn Belgium, according to the worldwide income principle, dividends received from participations are first included in the corporate tax basis and, later on, exempt under the so-called “dividend received deduction”. Following the Cobelfret case, an excess amount of dividend received deduction for one year can now be carried forward over an unlimited period; the carry-forward is limited to dividends received from EEA companies. Art. 198, 10°, BITC denied the deduction of interest as professional expenses up to an amount corresponding to the dividends available for the dividend received deduction. This provision has been repealed. However, a taxpayer is challenging its compatibility for the past with the Parent-Subsidiary Directive. The ECJ recently issued an Order whereby it rejects the claim for insufficient information given by the national jurisdiction to the Court in order for it to give an useful answer.6



Excess profit rulingsArticle 185, §2, b, BITC implements the arm’s-length principle between related companies as regards their cross-border relationships. It allows for adjustments in Belgium of profits which are included in the tax basis of the Belgian company and which are also included in the tax basis of another company, when such profits would have been realised by the other company under conditions agreed between independent companies. On that basis, so-called “excess profits rulings” have been issued, acknowledging that the not at arm’s-length part of the profits should not be taxed in Belgium, which the EU Commission is now challenging.According to the EU Commission, the Belgian excess profit rulings allows Belgian entities of multinational enterprises to reduce their tax base in a substantial manner, through unilateral downward adjustment granted by the Advanced Ruling Committee. The Commission at this stage considers Article 185 § 2 b) CIR92 together with the coherent ruling practice as a scheme which provides for a selective advantage tantamount to State aid and invites Belgium and the concerned companies (about 50) to explain their point of view.7 This action of the EU Commission does not target only Belgium, but results from its wider action against aggressive tax planning and thus concerns other similar Member States, the practices of which, in the field of transfer pricing, are also challenged.

Significant deals and highlights illustrating aspects of corporate tax and taxation of shareholders

Professional expenses and corporate purposeAccording to Art. 49 BITC, eligible for deduction are expenses made “with a view to acquire or preserve taxable income”; case-law has required that there be a genuine and necessary link between the expenses incurred and the business activity carried on. Those last years, the tax authorities regularly and successfully disallowed expenses relating to transactions – often steps in tax planning schemes – as being outside the scope of the corporate purpose of the taxpayer, ultra vires. The Supreme Court even decided that the deduction could be disallowed when the corporate purpose had been amended in full compliance with company law requirements, when it appeared that the amendment was part of a wider tax planning scheme.8 However, the taxpayers and their counsels continued to challenge that case-law. On 4 June 2015, the Supreme Court overturned its case-law,9 holding that there is no requirement under art. 44 of the former BITC (now art. 49) for the deduction of expenditures that they would be inherent to the company’s business as described in its corporate purpose clause in its articles. In other words, deduction of expenses and charges will no longer be disallowed for being ultra vires. No doubt that that holding will be welcomed by the academics and practitioners. Tax on the conversion of bearer securitiesIn 2005, Belgium decided, as part of its plan against abuse, financial crime, terrorist financing, money laundering and tax fraud, to abolish bearer securities by prohibiting as from 1 January 2008 the issuance and physical delivery of new bearer securities, converting by operation of law certain bearer securities into dematerialised securities and mandating conversion of other bearer securities into registered or dematerialised securities by 31 December 2013 at the latest.10 A tax was introduced by a law of 201111 on the conversion of bearer securities into dematerialised or registered securities, in accordance with the aforementioned law. The tax



amounts to 1 or 2 % of the shares’ value, depending on whether the conversion was effected in 2012 or in 2013. The Belgian Constitutional Court referred a preliminary ruling to the ECJ on the compatibility of that tax with the EU Directive 2008/7/EC on the raising of capital. On 9 October 2014,12 the ECJ ruled that “Article 5(2) of Council Directive 2008/7/EC of 12 February 2008 concerning indirect taxes on the raising of capital must be interpreted as precluding the taxation of the conversion of bearer securities into registered securities or dematerialised securities such as that at issue in the main proceedings. Such a tax cannot be justified under Article 6 of that directive”. By its judgment of 5 February 2015, the Constitutional Court annulled the tax, without any limitation at the time of its decision.13 As a rule, a tax undue as contrary to EU law must be reimbursed to the taxpayers, under the conditions of the national procedural rules applicable. Besides tax or civil procedures if any, according to Belgian law, a decision of annulment by the Constitutional Court opens a new deadline of six months as from the publication of the decision in the Belgian Official Journal, for requesting repayment of the undue taxes.In the case at hand, the person who paid the tax was either the company (for registered shares) or the bank (for dematerialised shares), and is different from the person who finally bears the tax. This raises practical difficulties since, as a rule, only the taxpayer is entitled to request repayment from the Belgian State, while the persons who bear the economic burden of the tax could only request a refund from their bank or the company itself. Provisions for risks and chargesProvisions for probable but uncertain risks and charges may be tax exempt under certain specific conditions. The tax authorities challenged some such provisions of which they had been accepting exemption for years, arguing that those provisions did not relate to specifically defined risks and were not justified by events having occurred in the course of the financial year. The Court of appeal ruled that the provisions were tax exempt and that the taxpayer could rely on the legal certainty principle.14 The judgment contains valuable insight into the relevant criteria for applying the tax exemption of provisions for risks and charges.

Key developments affecting tax law and practice

GAARIn our last review, we mentioned the introduction of a new anti-abuse rule allowing the revenue to set aside transactions or a series of transactions involving “fiscal abuse” for income taxes, but also for registration and succession duties, and VAT.There is fiscal abuse when a taxpayer avoids a tax burden or obtains a tax benefit in contradiction to the objectives of the relevant provision of the law; the taxpayer may prove that the transactions were justified by non-tax motives.If he fails, he will be subjected to tax according to the objectives of the relevant provision.We also mentioned the fact that the GAAR raises serious issues of constitutionality, considering that the tax must be established by an act of Parliament, not by judicial or administrative construction of its objectives. Belgium – as well as the other Member States – now has to transpose into Belgian law the changes introducing a new GAAR in the Parent-Subsidiary Directive.15 From a Belgian perspective, a first question might be whether the new domestic GAAR could function as a satisfactory transposition of the Directive or whether a SAAR should be introduced in the dividend received deduction regime.



FATCA and international exchange of informationIn our last review, we mentioned the IGA signed on 23 April 2014 by Belgium and the US, implementing FATCA for financial institutions. The Agreement is based on the Model 1 Reciprocal Agreement, meaning that FIs will have to report directly to Belgian tax authorities who will then report to the IRS. Belgium also agreed, with other States, like Switzerland or Singapore, to implement the OECD Common Reporting Standard (CRS) that should be effective by the end of September 2017. As an EU Member State, Belgium will also have to implement Directive 2014/107/EU modifying Directive 2011/16/EU as regards mandatory automatic exchange of information in the field of taxation. New treaty with Russia signedA new treaty was signed with Russia on 19 May 2015 based on the OECD Model; this treaty will replace the 1995 treaty. As regards dividends, the withholding tax at source is reduced to 5% of the gross amount of the dividends if the beneficial owner is a company which holds, for an uninterrupted period of at least 12 months, shares representing directly at least 10% of the capital of the paying company, provided this holding amounts to at least €80,000 or the same value in roubles. In other cases, the withholding tax is reduced to 15% of the gross amount of the dividends. However, no tax is due in the source State on dividends paid to a pension fund that is a resident of the other Contracting State, provided that such dividends are not derived from the carrying on of a business by the pension fund or through an associated enterprise.On interest, the withholding tax is limited to 10%. A full exemption applies to a) interest paid in respect of a loan granted or a credit extended by an enterprise of a Contracting State to an enterprise of the other Contracting State, b) interest paid to a pension fund, provided such interest is not derived from the carrying on of a business by the pension fund or through an associated enterprise, and c) interest paid to the other Contracting State, to one of its political subdivisions or local authorities or to a public entity. The treaty is completed by an LoB clause and provisions on mutual exchange of information and assistance for the recovery of taxes. It is also worth noting that: • the treaty specifies that the place of effective management of a company is determined,

among others, by the following criteria: the place where the board of directors or equivalent body holds its meetings; the place where the senior day-to-day management is carried on; and the place where the senior executives carry on their activities (art. 4.3);

• the provision on income from immovable property applies to the income of a resident of a Contracting State from units of fiscally transparent mutual investment funds organised in the other Contracting State primarily for the purpose of investing in immovable property situated in that other State; while

• the definition of dividends includes payments on units of fiscally transparent mutual investment funds other than those subject to the immovable property provision;

• specific provisions on pensions completed by a clause in the Protocol according to which the applicable rule on pension contributions to recognised pension scheme is modified should Russia later sign a treaty with another state containing such provision; and

• the Protocol to the Convention also includes a clause obliging the tax authorities of both States to interpret the treaty provisions which are identical or in substance similar to the provisions of the OECD Model of 1977 (with later amendments) according to the OECD Commentary (unless disagreement is expressed).



Tax on so-called “secret commissions”A “secret commissions” 309% tax applied on hidden profits, but also on amounts which had not been properly reported on salary slips. Since 2010, the tax authorities applied the provision strictly regarding unreported benefits in kind. A law of 2013 introduced some softening. This regime is modified by the Law of 19 December 2014. Salaries, remunerations and benefits in kind that are not properly reported, hidden profits and financial advantages resulting from bribery are subject to the secret commissions tax. Hidden profits no longer include expenses that are disallowed as “professional expenses”. The tax rate is now reduced to 103% or, when the beneficiary is a legal entity, 51.5%. The tax does not apply under certain conditions if the expense or benefit in kind is taxed in the hand of the beneficiary within a specified time. The secret commissions taxation itself is tax deductible and the underlying expense is or is not tax deductible depending on its nature. The new regime applies as from 29 December 2014 and extends to all disputes that are not finally settled on that date. Corporate tax on intermunicipal entitiesSome public entities – so-called intermunicipal entities (“intercommunales”) – are organised under the form of commercial entities. They were specifically excluded from the corporate tax and subject to legal persons tax which results in lower taxes. Other entities, although also organised by municipalities, do not benefit from this exclusion and are subject to corporate taxation. The Constitutional Court recently ruled that the latter were discriminated against and thus were entitled to the exemption.16 Furthermore, many of these intermunicipal entities are in direct competition with private undertakings which are subject to corporate or individual income taxation; the question is thus raised of a potential state aid in favour of intermunicipal entities.17 The legislator recently decided to repeal the exemption of corporate income tax in favour of these intermunicipal entities. This does not mean that all entities at hand are now to be subject to the corporate income tax; indeed corporate taxation requires the company to be engaged in an exploitation or in lucrative operations. Intermunicipal entities which are not so engaged will remain within the scope of the legal persons tax; this is a matter of fact and will raise practical difficulties. It is likely that some of these entities will petition for annulment before the Constitutional Court. One of the arguments could be that the law applies with a kind of retroactive effect insofar as existing reserves which have not been taxed under the former regime are now within the scope of corporate taxation and will be liable to a 33.99% taxation. It is now suggested that the legislator could recant on this subjection to corporate taxation and exempt again certain intermunicipal entities active in specific sectors, such as hospitals. Retroactivity clause for reorganisationsIn practice, a retroactivity clause for accountancy and tax purposes is regularly included in case of reorganisation through merger or demerger. The Belgian tax authorities usually accept such a clause insofar retroactivity does not exceed six or seven months. In a recent ruling however, the tax authorities accepted a retroactivity between nine and 11 months, in the case of cross-border mergers by a Belgian company with French and German companies, on the condition that the transaction is realised under the neutrality regime and does not prevent a just application of tax law.18 This longer retroactivity was justified by lengthier formalities to be accomplished in the various states in order to complete the transaction.



Attracting holding companies

The regime for companies holding shares on a durable basis (one year) is rather attractive: • dividends received are 95% tax exempt, the balance being subject to tax at the ordinary

rate of 33.99%; • related expenses, and notably interest on funds borrowed for acquiring shares, are

deductible; and• capital gains are subject to tax at 0.412%, realisation expenses being, however,

disallowed; if the shares are realised after less then one year, the gain is taxed at the special rate of 25.75%.

Outgoing dividends are liable to withholding tax at 25%, which is however waived for corporate shareholders at more than 10%, not only for EU beneficiaries, but also for beneficiaries in treaty countries, provided the treaty allows full exchange of information. More widely, considering the ECJ case-law in the field of cross-border losses compensation, one should consider the interest of the Belgian tax rules: Belgium taxes worldwide income (this implies compensation of all profits and losses worldwide), and exempt the profits from foreign PEs (thus not including losses in the exemption). Therefore, the global tax burden of taxpayers for years showing a loss corresponds to the best way to the tax on the economic income.

Industry sector focus

The tax shelter for the film industry has been redesigned. The maximum benefit is obtained for a production budget of €1.4m including €900,000 total expenses (of which €630,000 are “direct” expenses) in Belgium; the producer then can receive up to €483,000 in non-refundable “investments”. The corporate investor may shelter 310% of his investment – thus a tax benefit of 105.37% recouping the lost investment and including an extra benefit – and be secured a financial return of €LIBOR 12 months + 4.5%.A draft Bill has recently been submitted by the Government, including some important tax changes, amongst which are the: • introduction of a “diamond tax” in order to tax diamond traders on their turnover at a

(low) flat rate; this regime is inspired by the “tonnage tax” for the shipping industry; and • introduction of a so-called “Cayman tax”, targeting income from certain legal

construction in the hands of Belgian individuals and Belgian entities subject to legal entities income tax: the Belgian legislator wants to apply a transparency regime to such entities. However, no taxation occurs if the legal construction bears a tax burden of at least 15% on a tax base determined according to the Belgian income tax rules.

The relevant legal constructions include, a.o., trusts, foundations, private undertakings for collective investments, pension funds when not publicly traded, low-taxed or non-taxed entities, etc. Undertakings for collective investments and pension funds which are publicly traded, listed companies, are not considered legal constructions. As a rule, legal entities within the EU are not considered as legal constructions except for entities that will be listed by the Government. The tax is due by the founder or the beneficiary of the legal construction who is a Belgian resident. The Draft Bill also includes some new incentives in favour of new enterprises and specific sectors, a.o.: • “Tax Shelter” in favour of new enterprises: it is intended to grant individuals a tax

reduction corresponding to 30% of their investment (limited to €100,000) as equity



contribution into newly created SMEs, directly or through a specific crowdfunding platform. The tax reduction will be granted under certain conditions mainly relating to the time of the acquisition of the new shares and the company to which a contribution is made. The shares must be kept for at least four years.

• Exemption of interest received from newly created enterprises: interest relating to the first €15,000 lent for at least four years by an individual taxpayer, acting as a private individual, in order for the borrowing enterprise – be it a company or an individual enterprise, but newly created – to finance economic projects will be tax exempt.

• SMEs will also be granted an increased deduction for their digital investments.

* * *

Endnotes

1. ECJ, 25 October 2012, case C-387/11. 2. Pending case C-589/14. 3. Pending case C-48/15. 4. Const. Court, 28 January 2015, No. 11/2015. 5. Pending case C-68/15. 6. ECJ Order, 4 June 2015, case C-578/14, Argenta Spaarbank NV c. Belgian State. 7. OJEU, 2015, C188, p. 24. 8. Supreme Court, 9 November 2007, www.fiscalnet.be.9. Unpublished at this date. 10. Law of 14 December 2005, Art. 3 et seq. (M.B., 23 Dec. 2005). 11. Law of 28 December 2011, introducing new provisions into the Code of various taxes

(M.B., 20 December 2011).12. ECJ, 9 October 2014, C-299/13, Gielen c. Ministerraad. 13. Case No. 12/2015. 14. Court of Appeal of Antwerp, 21 April 2015, unpublished. 15. Council Directive (EU) 2015/121 of 27 January 2015 amending Directive 2011/96/

EU on the common system of taxation applicable in the case of parent companies and subsidiaries of different Member States.

16. Cases 2012/148 dated 6 December 2012 and 2014/114 dated 17 July 2014. 17. See the infringement procedure of the EU Commission against The Netherlands

(IP/14/794). 18. Tax ruling of 15 April 2014, No. 2014.133.


Philippe MalherbeTel: +32 2 551 15 77 / Email: [email protected] Malherbe has substantial experience in transactions from both the corporate and tax law points of view. He focuses on solving problems through creative structural solutions and win-win negotiation. When necessary he litigates.He has authored Elements of International Income Taxation (Bruylant, 2015) and co-authored a standard textbook on company law. He frequently lectures on those topics.Philippe is professor at the Catholic University of Louvain, where he teaches European and international tax law, corporate income tax, special topics of company law, and international business law and visiting professor at the University of Paris-Est Créteil where he teaches comparative taxation.He holds both an economics degree (1976) and a law degree (1977) from the University of Louvain and an LL.M. (1978) from the University of California, Berkeley.Philippe joined Liedekerke Wolters Waelbroeck Kirkpatrick in 1978 and has been a Partner since 1985.

Isabelle RichelleTel: +32 2 551 16 90 / Email: [email protected] Richelle is of counsel at the Liedekerke law offices, where she is a member of the Tax Group. She practises all aspects of tax law and, in particular, corporate taxation, European and international taxation, and environmental tax. She specialises in restructurings, real estate tax and wealth planning.She is a member of several scientific organisations. She is the author of many publications and speaks regularly at conferences. Isabelle is also a deputy judge at the Namur Court of First Instance.Since 2011, she has been co-president of the Tax Institute of the University of Liège (ULg) and she has been a professor of taxation at the HEC Business School of ULg since 1987. She teaches European tax law and income tax law. Isabelle holds an advanced degree in tax law (ULg) and a Ph.D. in law (ULBrussels) for her dissertation “Concept and treatment of losses in tax law − National and international aspects”.Isabelle joined Liedekerke Wolters Waelbroeck Kirkpatrick in 2006 after having spent several years working as a senior manager for an international consulting firm.

Liedekerke Wolters Waelbroeck KirkpatrickBoulevard de l’Empereur 3 Keizerslaan – B-1000 Brussels, Belgium

Tel: +32 2 551 15 15 / Fax: +32 2 551 14 14 / URL: http://www.liedekerke.com


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