Sweden & Belgium: Heightened Scrutiny of Local Activities

The tax authorities in Sweden and Belgium (indeed throughout the EU) have become increasingly sensitive to the local activities of foreign companies.  In recent months, they have launched detailed investigations into payroll-only registrations of overseas companies/employers to determine if the activities of employees, along with other commercial dealings, may constitute permanent establishment. 

The findings not only have direct impact on an employer’s liabilities related to corporate tax and social security contributions, they also have larger VAT-related implications and likely commercial insurance considerations as well.

It is therefore of paramount importance that clients without a legal entity presence in country have a clear understanding of the activities undertaken by their employeesto ensure that proper registrations are undertaken from the outset. These may include a payroll registration (which may be “with” or “without” a PE registration), or some other form of legal entity that may be appropriate for the activities being undertaken.

If you are concerned about the current validity of your payroll only registrations in country, please contact Advisory and we can arrange to review your commercial activities against the current (and frequently changing) registration requirements.