Millions of euros in fees for the agent of Luka Modri\u0107 – Belgium-based Vladica Lemi\u0107 – were paid to a company in Bosnia & Herzegovina, owned by his younger brother Zoran Lemi\u0107. <\/b>Corporate tax in Bosnia & Herzegovina is only ten percent, over three times less than the rate in Belgium, where Lemi\u0107 is resident, raising issues of potential tax fraud.
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Lawyer of Belgian firm Bloom Law, Denis-Emmanuel Philippe, tax professor at University of Li\u00e8ge, analysed anonymised findings and calculations of this investigation and confirmed this might be a tax fraud. He said that if \u201cin principle\u201d the consultancy services have been rendered out of Belgium, the consultancy fees would need to be taxable in Belgium at the corporate income tax rate of 33.99 percent.<\/p>\n
***<\/p>\n \u201cIn the case at hand, the question arises whether the profits derived from the consultancy services have been artificially shifted to a low-tax country, [such as Bosnia]. Such would be the case if the key people, which create the added value with respect to the consultancy services rendered, [included] a Belgian tax resident who performs the services out of Belgium.\u201c<\/p>\n ***<\/p>\n \u201cSuch a situation is a typical case of tax fraud: reality does not match with the contractual arrangements,\u201d added Philippe.<\/p>\n ***<\/p>\n \u201cIf there is a tax fraud, criminal sanctions are also not to be excluded,\u201d he added.<\/p>\n