Making a non-profit entity liable for tax on legal persons

Non-profit organisations which, in addition to their disinterested activities, carry out an economic activity risk becoming subject to corporation tax if they are unable to prove that they meet the conditions for remaining subject to corporation tax.

This implies that the ASBL, AISBL or foundation that wishes to maximise its chances of being subject to corporate income tax must provide proof that it meets the conditions.

This proof should, in theory, be able to be provided by the association on an annual basis. It is important to put in place a strategy that enables it to be produced in the event of a tax audit.

Otherwise, the tax inspector will not hesitate to make the association liable to corporation tax, leaving the ASBL, AISBL or Foundation only the possibility of lodging an appeal against this liability if it contests it.


Our intervention consists in :

  • providing you with the theoretical background enabling you to identify, in particular:
    • the differences between the IPM and the ISOC and the implications of being subject to the ISOC
    • the conditions for exemption and the evidence to be provided
  • provide you with our recommendations based on our understanding of the planned activities.

In concrete terms, the intervention takes place as follows:

  • we give you a questionnaire to fill in, allowing us to identify your activities precisely.  If necessary, a video call is organised.
  • we send you a theoretical note as well as access to an interactive visual that allows you to approach the subject in a didactic way.
  • we invite you to a workshop, either face-to-face or by video conference, according to your choice, during which:
    • we check your understanding of the theoretical background
    • we comment on your activities
    • we formulate our recommendations.
  • we provide you with a closing note.

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