On 25 March, the Special Tax Inspectorate sent a sub-assessment of €9.7 million to NV Elzenwalle, a subsidiary of Gheysens’s Ghelamco real estate group. This is stated in the explanatory notes to Elzenwalle’s recently published annual accounts. Elzenwalle refers to the castle between Ypres and Kemmel which is the home of (or one of) Paul Gheysens.
The discussion with the tax authorities revolves around a transaction in Poland. In 2004, Elzenwalle acquired 60% of the Polish company Apollo Invest for €237,631. The company was the owner of the prestigious unit project in Warsaw (DAny picture, central skyscraper). Ghilamco built a 46-story skyscraper there, including a viewing platform with a tilting glass floor.
Nothing Wales
In September 2016, before construction of the skyscraper began, Elzenwalle transferred her 60% stake in Apollo Invest to Granbero Holdings, a Cypriot subsidiary of Ghelamco. In return, Elzenwalle received shares in Granbero Holdings for €33 million. This stake was immediately sold to the Ghelamco group for the same amount, De Tijg reported.
Elzenwalle recorded an extraordinary financial return of EUR 33 million as a capital gain on tax-exempt shares. The Special Tax Inspectorate did not approve this. The BBI did not consider the EUR 33 million as a capital gain on shares, but rather as an abnormal or favourable advantage, for which there was no actual consideration.
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