Contribution à l’étude du régime de fiscalité directe des entreprises sociales en Belgique

n Europe, a social enterprise engages in economic activity while pursuing a social purpose and implementing inclusive governance. Following the discourse of international authorities, in a perspective favorable to their development and sustainability, social enterprises should not be taxed in the same way as commercial enter-prises, insofar as such a tax burden could, in the long term, threaten their viability (need for an “appropriate and coherent fiscal framework”). Through a retrospective, descriptive and prospective study, we can conclude that, as far as income taxes are concerned, such an appropriate and coherent tax framework does not exist in Belgium and that the introduction of such a framework would require a paradigm shift: it is no longer the realization of profits that should determine the tax regime but the allocation reserved for those profits.