The system is based on the idea that part of the profits international companies book in Belgium is due to the fact that they are active across the globe. Belgium did not levy tax on this international part of their profits. In this way, Atlas Copco that was the most frequent user of the ruling system did not pay tax on 517 million euros.
The 36 companies together didn't pay any tax on two billion euros. Their total tax advantage was worth 700 million euros. The European Commission now wants the Belgian government to recoup this tax advantage. The commission sees the measure as a form of illegal state aid.
The list contains famous international names like oil giant BP and pharmaceuticals multinational Pfizer, but also smaller Belgian companies like Kinepolis, Omega Pharma, Ontex and Soudal.
Belgium and the EC had agreed to keep the list confidential, but the names have now leaked in the dailies De Tijd and De Standaard.
One of the companies involved, Germany's BASF, underlines it did not do anything illegal. The Belgian authorities offered BASF the arrangement, it stresses pointing to the extra investments that led to additional jobs.
Atlas Copco too points to the new division that was set up as a result of the tax regime and the extra jobs and claims Belgium is now failing because it is no longer providing certainty for future investments.
The Belgian government still has to decide on whether to appeal against the EC's decision. Belgian Finance minister Johan Van Overtveldt first wants to hear what procedure the EC believes Belgium should use to recoup the monies due.
Mr Van Overtveldt says it's unclear whether Belgium will be able to recoup any cash and fears companies will take Belgium to court. He held a joint meeting with the companies concerned last week with a view to drawing up a common strategy.