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International Tax Update: Digital Service Tax: Dead and done with?
On 8 October 2021, the already historical agreement about Pillars I and II was reached between 136 member jurisdictions of the OECD/G20 Inclusive Framework. A part of the overall agreement…
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International Tax Update: Recent tax developments in Germany
German Real Estate Transfer Tax Rules for share deals As in Belgium, German Real Estate Transfer Tax (“RETT”) is triggered by the notarization of a direct real estate purchase. The…
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Belgian Annual Tax on Securities Accounts challenged before Constitutional Court: annulment appeal is no suspension
With its Law of February 17, 2021, Belgium introduced a new annual tax on securities accounts (hereafter: “ATSA”), which has replaced the previously annulled tax on securities accounts that the…
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International Tax update: Belgian Transfer Pricing Court Case
In a recently published decision dd. 8 June 2021 of the Court of Appeal of Ghent relating to transfer pricing (nr. 2016/AR/455), the Court decided in favor of the taxpayer.…
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International Tax update: The Belgium - Luxembourg 24 day-rule becomes the 34 day-rule
The salary of a Belgian tax resident relating to days performed in Luxembourg is generally taxable in Luxembourg according to the Belgium-Luxembourg double tax treaty. The days worked outside of…
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Luxembourg Newsflash: New administrative circular sets guidelines for the imposition of tax fines
The 2017 tax reform significantly strengthened the power of the Direct Tax Authorities to impose tax fines on taxpayers found in infringement of their tax obligations. In this scope, the…
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VAT and e-commerce: Belgium implements new rules on importer of record
Following the adoption of the law implementing the new e-commerce VAT rules in Belgium, a Royal Decree has been published on 29 June 2021, amending several earlier Royal Decrees on…
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International Tax update: Evolving towards more OECD-compliancy: the times are changing in the Middle East
The Middle Eastern leg of the Tiberghien world tour showed some interesting developments in tax legislation of this region. These (expected) changes will undoubtedly have a big impact on MNE’s…
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Can tax related and IT services benefit from the VAT exemption for the management of special investment funds? The European Court of Justice says yes.
The Court of Justice of the European Union (ECJ) ruled in the joined cases K (C-58/20) and DBKAG (C-59/20) that the management of tax related responsibilities and the supply of…
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International Tax update: Mutual tax agreements mitigating the impact of Covid-19 telework for internationally active employees extended until the end of 2021
UPDATE 28/09/2021 Due to the Covid-19 pandemic, most employees have worked from home for a large number of days from March 2020 onwards. As the taxation of salaries and the applicable…
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International Tax update: Biden’s Green Book and the Old Continent
Last week the US Treasury Department released the long-awaited “Green Book”, explaining the tax proposals of the Biden Administration. The final version is shorter and less detailed than expected. Nevertheless,…
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