The tax authorities announced several changes today, 28 April 2020, in respect to the expat tax regime and its application procedure.
First, the department where the formal request should be sent changes its name to ‘Specific Matters Center’ (Centrum Specifieke Materies/Centre Matières Spécifiques) instead of ‘Foreign Center’ (Centrum Buitenland/Centre Etranger). However, the contact details remain the same and the address is still located at Kruidtuinlaan 50 / 3410, 1000 Brussels.
The tax authorities also confirmed that they are currently developing an automated system to deal with the expat applications. We really hope this system will be in place soon, as the applications still need to be filed the old-fashioned way and there is no easy way to check if a request was correctly received or not.
Another important announcement is that the tax office now also introduced a ‘prefiling’ option. We are already familiar with this term as it has been used for many years by the Ruling Commission (for advance tax decisions), but apparently now also found its way to the expat application process.
In case of more complex situations, it will allow the applicant or its representative to check the tax authorities’ position beforehand on a certain element of the application. It will help to assess whether a formal request is advisable and if there would be any chance of the request being refused. It is not yet clear if this ‘prefiling’ can also be done on an anonymous basis.
The ‘prefiling’ process can be initiated via email (email@example.com) or via regular mail to the above mentioned address.
The processing time by the authorities of the ‘prefiling’ procedure should be around 6 weeks and it obviously does not replace the actual application itself. If the prefiling has the desired outcome, the request would still need to be filed afterwards within the standard 6-month deadline.
We sincerely hope that this may be the starting point for a further digitization and increased transparency regarding the application procedure for the expatriate tax status.