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Breaking - The new double taxation treaty between the Netherlands and Belgium

Friday, 30 June 2023
On 21 June Belgium and the Netherlands signed a new double tax treaty on income taxes. Unlike under the current treaty, the scope of this treaty will be limited to…
News

Brazil’ legislator enacts new transfer pricing law

Friday, 30 June 2023
On 15 June 2023, Brazil published a new law establishing a transfer pricing framework that is aligned with the OECD Transfer Pricing Guidelines (“OECD TPG”). Reforming Brazil’s transfer pricing (“TP”)…
News

Luxembourg tax authorities issue guidance on reverse hybrid rules

Tuesday, 20 June 2023
On 9 June 2023, the Luxembourg direct tax authority (Administration des contributions directes, the “ACD”) released a 3-page circular – L.I.R n°168quater/1 (“Circular”) in relation to the so-called reverse hybrid…
News

Cross-border telework: increase of social security threshold to 49%

Wednesday, 10 May 2023
The Administrative Commission for the Coordination of Social Security Systems of the European Union proposed a standard agreement aiming to increase the social security “threshold” for cross-border telework as from…
News

The recent tax and social security reforms on copyright income: what employers need to know

Wednesday, 03 May 2023
Following an intense debate, the legislator introduced a new tax scheme applicable to copyright income. Main raison for this initiative is the assumed abuse of the until then beneficial tax…
News

Are the tax authorities ‘partying with you on stage’?

Monday, 13 March 2023
Many festivals have announced the first names for spring and summer 2023. We explain below the tax obligations for festival organisers with foreign artists on the bill.
News

Amendments to Hong Kong tax regime not sufficient? Update of the EU list on non-cooperative jurisdictions

Tuesday, 21 February 2023
Last week, the ECOFIN meeting of the Council of the EU took place, deciding on an update of the list of non-cooperative jurisdictions (the “black list”) and the list of…
News

Luxembourg double tax treaties update : UK, France and Germany

Monday, 13 February 2023
On 20 January 2023, the Luxembourg Council of Government took two different important decisions.  
News

Christophe Dillen joins the partners of Tiberghien

Tuesday, 31 January 2023
Tiberghien continues to grow and evolve to provide its clients with forward-looking services of the highest standard. It is therefore with great pleasure that we announce the appointment as partner…
News

ATAD 3 and more: a brief update

Tuesday, 31 January 2023
In December last year, the European Parliament published a resolution on the proposal for a Directive laying down the rules to prevent misuse of shell entities for tax purposes (so-called…
News

An informal gift by way of bank transfer in cross-border context: points of interest

Thursday, 26 January 2023
The gift by way of bank transfer is a popular technique for making gifts to children or grandchildren. As this article will show, it involves more than simply transferring money…
News

Pillar Two/IFRS Newsflash: IASB consultation on IAS 12 amendements for Pillar Two

Thursday, 12 January 2023
On 9 January 2023, the International Accounting Standard Board (IASB) published Exposure Draft ED/2023/01 which contains important proposed amendments to IAS 12, the International Accounting Standard dealing with accounting for…
News

Belgian expat tax regime now extended to foreign non-profit organisations

Tuesday, 10 January 2023
On 1 January 2022, a new expat tax regime was introduced in Belgium that provides for a favourable income tax (and social security) treatment for employees, directors and researchers recruited…
News

Pillar Two - OECD’s Recently Released Safe Harbours and Penalty Relief Guidance : Solving key issues that MNEs face, or just a drop in the ocean?

Friday, 23 December 2022
On 20 December 2022, the OECD/G20 GloBE (Global Anti-Base Erosion) Inclusive Framework released, as part of a broader package[1], its Pillar Two Safe Harbour and Penalty Relief guidance document. Numerous…
News

Belgium - Luxembourg 34-day rule to be approved before year-end

Tuesday, 20 December 2022
On 31 August 2021, Belgium and Luxembourg signed a protocol increasing the 24-day tolerance to 34 days as from 2022.
News

Breaking: the EU’s Pillar Two Directive received required unanimous support

Tuesday, 13 December 2022
As mentioned in a previous newsflash, the EU Council published a slightly revised draft of the Pillar Two Directive on 25 November 2022. This was done in an attempt to…
News

Partial VAT deduction applying to the real use method: major changes from 1 January 2023

Tuesday, 13 December 2022
Existing cases: notification required by 30 June 2023 at the latest!
News

International Tax Update: The rise of the interest rate and the impact on valuations and transfer pricing

Wednesday, 07 December 2022
Behold, the era of free money is no more. This might be hard to digest for governments, companies and investors alike. After an extensive period of record-low interest rates and…
News

Newsflash: EU Council publishes updated draft Directive on global minimum taxation (Pillar Two) in light of next ECOFIN meeting of 6 December

Friday, 02 December 2022
Last year, the European Commission published, as a Christmas present, a proposal for a Directive on ensuring a global minimum level of taxation for multinational enterprise groups and large-scale domestic…
News

Luxembourg: interest free loan reclassified into equity – decision Administrative Tribunal

Thursday, 01 December 2022
In the judgement n°44902 dated 23 September 2022, the Tribunal Administrative (the “Tribunal”) requalified an interest free loan granted by a parent company to its subsidiary into equity on the…
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