1. Apportionment of Gross Profit of Local Branch to Real Centre of Management abroad
When assessing the profits derived from operations carried on in Belgium, no fraction of these profits is attributed to the real centre of management abroad.
As explained above (page 78), tax is assessed in Belgium upon the profit from all operations conducted in the country by or through the Belgian establishments, the only deduction allowed being the professional expenses of the Belgian office. The Belgian establishment is considered separately for the purpose of determining profits and therefore none of these are ascribed to the real centre of management abroad.