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BREAKING NEWS: The UK Spring Budget 2024: Replacement of the “non-dom” tax status (RND) by a new four-year foreign income and gains (FIG) regime as of 6 April 2025 – impact on Income Tax, Inheritance Tax (IHT) and trusts

Friday, 15 March 2024
The UK recently announced important tax reforms in its Spring Budget 2024. The proposed changes are relevant for individuals who are resident but not domiciled in the UK (so-called “non-doms”…
News

​Rules on allocation of taxing rights on immigration and emigration of individuals under the new Belgian - Dutch Double Tax Treaty: main changes ​

Monday, 04 March 2024
​In an earlier article in this series, we already discussed the planned changes in terms of moveable income. Whilst the changes may seem relatively limited at first glance, Dutch residents…
News

Navigating the Nuances: The Administrative Court's Interpretation of Loan vs. Equity Characteristics

Thursday, 29 February 2024
On 23 November 2023, in case number 48125C, the Luxembourg Administrative Court overruled a decision rendered by the Administrative Tribunal on 23 September 2022.
News

Tiberghien moves to Tweetorenwijk in Hasselt

Thursday, 22 February 2024
We are proud to announce our new location in the heart of Hasselt. This move represents a significant strengthening of our presence in the region.  
News

New Belgium-Netherlands double tax treaty - Permanent establishment provisions amended in line with MLI

Thursday, 15 February 2024
The new double tax treaty between Belgium and the Netherlands will introduce significant changes  compared to the current Article 5 on permanent establishments. Due to the positions of Belgium and…
News

(Shareholders of) corporate groups: beware of new CFC and cayman tax rules

Thursday, 08 February 2024
The Belgian legislator adopted new legislation on December 22, 2023, significantly modifying two sets of rules: (i) the CFC rules (“Controlled Foreign Corporation rules”) applicable to Belgian corporate taxpayers and…
News

Withholding tax on Dividends, Interests and Royalties under the new Belgian - Dutch double tax treaty - Main changes

Tuesday, 16 January 2024
The withholding tax jurisdiction of the source state is limited to 15% for dividends, as before. Withholding tax may (no longer) be withheld when dividends are paid by subsidiaries to parent companies…
News

European Court of Justice ruling: end of the application of VAT on director fees in Luxembourg

Thursday, 04 January 2024
On December 21, 2023, the European Court of Justice (“ECJ”) issued its long-awaited ruling in the case C288/22 “TP” on the VAT treatment of director fees. From a Luxembourg VAT…
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Belgium: The Belgian government also intends to, officially, make B2B e-invoicing mandatory

Monday, 08 January 2024
On 28 December 2023, the Belgian government submitted its proposal for a mandatory B2B invoicing scheme. Rumors for such an obligation were there since the end of 2022 and during…
News

CAYMAN TAX 2.1 – sharpened teeth or mere dentures? A first update based on the draft bill as finally submitted to parliament.

Wednesday, 13 December 2023
PREFACE : This newsletter is only a first brief look at yet another very complex draft of cayman tax adjustment. Further analysis is recommended. This is an update of the…
News

Luxembourg minimum net wealth tax provisions declared partly unconstitutional

Tuesday, 12 December 2023
Main takeaways On 10 November 2023, the Luxembourg Constitutional Court ruled that certain provisions of the Luxembourg minimum net wealth tax were contrary to constitutional principle of equality. Pending a…
News

CAYMAN TAX 2.1 – sharpened teeth or mere dentures?

Friday, 03 November 2023
The draft bill approved at the Council of Ministers meeting on Friday, Oct. 27, 2023, proposes a whole number of changes to the cayman tax to ensure - in its…
News

Two new partners join the ranks

Tuesday, 24 October 2023
Tiberghien is known for its long and rich tradition and is determined to continue its successful path forward. The firm is therefore constantly looking ahead, scanning opportunities for future investments…
News

BEFIT, towards a common corporate tax framework in the EU ?

Friday, 13 October 2023
BEFIT stands for “Business in Europe: Framework for Income Taxation” and is the object of a draft EU directive proposed by the European Commission on 12 September 2023 (the “Draft…
News

BREAKING NEWS: The new tax treaty between Luxembourg and the United Kingdom enters into force

Tuesday, 10 October 2023
On 4 October 2023, the law of 18 September 2023 was officially published in the Memorial (the Luxembourg official gazette), so that the new tax treaty between Luxembourg and the…
News

Cayman tax remains applicable under new Dutch-Belgian double taxation treaty

Monday, 28 August 2023
The interaction of the Belgian cayman tax with the various double taxation treaties concluded by Belgium has been the subject of discussion in practice for several years. The question now…
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Accounting reform in Luxembourg - Draft law submitted to parliament

Thursday, 17 August 2023
Luxembourg government launched the first step of a reform of the Luxembourg accounting legal framework. The main objective is to consolidate into one single law the Luxembourg accounting rules currently…
News

New double taxation treaty between Belgium and the Netherlands - implications for individual investors

Monday, 17 July 2023
The double taxation treaty between Belgium and the Netherlands, signed on 21 June 2023, will result in certain changes for private investors. The main concerns are the impact on the…
News

Cross-border telework in Luxembourg: ongoing developments

Monday, 10 July 2023
Under the EU social security Framework Agreement, Luxembourg cross-border workers may telework more often from their state of residence without impacting their applicable social security legislation (provided telework represents less…
News

CBAM regulation adopted on 10 May 2023

Monday, 10 July 2023
On 10 May 2023, the Council of the European Union and the European Parliament adopted the new regulation (EU) 2023/956 establishing a carbon border adjustment mechanism (CBAM). CBAM is designed…
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