Comparison of VVPR-bis and liquidation reserves

VVPR-bis

The VVPR-bis scheme offers a reduced rate of withholding tax (Pr M) on dividends from cash contributions to “small” companies. These contributions must be fully paid up at the time of issue of registered shares, without preferential rights, made after July 1, 2013. Dividends benefit from this reduced rate progressively (30% in the first year, then 20% and 15% from the third year onwards). If the shares are sold, the new owner loses this benefit.

Pr M on liquidation reserves

This system allows a reduced rate of Pr M on liquidation reserves, with a contribution of 10% when they are set up. If the reserves are distributed at least five years after their creation, the Pr M rate is 5%. Otherwise, it is 20%. This regime also applies to liquidation surpluses without Pr M. The sale of shares does not alter this regime for the purchaser.

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