During our observation period 1997–2002, Belgian firms reporting a non-zero positive
taxable income were taxed at a statutory tax rate of 40.17%. This percentage contains 39%
basic statutory corporate tax on taxable income, plus a 3%(of 39%) austerity surcharge (i.e. a
surcharge, introduced by the Belgian government in 1993 for budgetary reasons).6 Fiscal
consolidation is not allowed in Belgium. Taxes are levied at the individual affiliate level and
not at the consolidated business group level (OECD, 2004). Belgian holding groups therefore
do not automatically benefit from the leveling out of positive and negative income numbers
from group members in their average tax bill.