The salary split theory for Belgian residents

A salary split is a remuneration technique often used for employees and directors who exercise their professional activities in more than one country.

The split taxation of income is the result of the application of bilateral treaties for the avoidance of double taxation. Under certain conditions, professional income is on the basis of such treaties allocated over several states for tax purposes.

The consequence of this principle is that the total tax burden on the salary can be reduced, as most countries have progressive tax rates. Because a salary split implies that the total income is not taxed in one state but spread over several states, the progression mechanism may be moderated.

 1  Tax aspects

• generalities
• salary split for employees
• salary split for directors

2 Practical aspects  

3 Social security impact   

• activities exercised in Belgium and in a member state of the EU or the EEA
• activities performed in Belgium and in a country with which Belgium has a bilateral social security treaty
• activities performed in Belgium and in a country with which Belgium has no bilateral social security treaty