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News 8th of December 2022 By Hannelore Durieu and Karlien Van Melkebeek

Change in the taxation of foreign directors’ fees for Dutch directors and the consequences for Belgian remuneration

On 1st January 2023 a major change will take place in the Netherlands with consequences for Dutch directors of foreign, in this case Belgian, companies. The tax exemption that currently applies in the Netherlands for the remuneration of foreign directors will soon no longer be applicable. We explain the change below.

Current situation

Situation as of 2023


Exemption method
Credit method
Worldwide income 100100
Dutch taxation 49.5%49.549.5
Foreign income5050
Foreign taxation2020
Avoiding double taxation50/100 x 49.5 = 24.75 49.5 – 20 = 29.5
Total Dutch tax49.5 – 24.75 = 24.75
If you have questions about the impact of this change on the directors in your organisation, definitely get in touch with one of our specialists.
Do you have any questions?
Should you have any questions regarding this subject, please do not hesitate to contact one of our specialists.
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We base our advice on current legislation, interpretations and legal doctrine. This does not prevent the administration from being able to challenge it or to change existing interpretations.
Hannelore Durieu
Hannelore Durieu
Karlien Van Melkebeek
Karlien Van Melkebeek