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The CJEU’s Wereldhave judgment: Dutch investment funds with “Fiscal Investment Institution” status do not fall within the Parent-Subsidiary Directive’s scope
Wednesday, 26 April 2017
26-04-2017 Facts Two Dutch companies, Wereldhave International and Wereldhave, respectively own 35% and 44% of the Belgian company, Wereldhave Belgium. Both Dutch companies have the “Fiscal Investment Institution” (“fiscale beleggingsinstelling”)…
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Taxation of pensions paid by Belgian debtors to non-residents: change of rules
Wednesday, 26 April 2017
26-04-2017 Pensions subject to Belgian non-resident income tax The Belgian Income Tax Code provides, as a basic rule, that occupational pensions paid to non-resident individuals are subject to tax in…
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Belgium introduces exit tax rules as it implements ATAD
Thursday, 06 April 2017
06-04-2017 - Belgium introduces a deferred payment regime for companies required to pay exit taxes on the cross-border relocation of assets, migration or restructuring in line with the EU Anti-Tax…
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Tiberghien’s continued growth
Tuesday, 04 April 2017
03-04-17 In recent years, tax law firm Tiberghien has seen tremendous growth. Now, in addition to this organic growth, the tax lawyers of the law firm Dauginet, will be joining…
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New Belgian Innovation Profits Deduction (“IPD”)
Tuesday, 14 March 2017
2017-03-14 - After the abolition of the patent income deduction, the Belgian government announced on 2 December 2016 a new tax deduction for innovation profits. In line with the OECD’s recommendations…
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VAT advance payments for quarterly VAT returns abolished from 1 April 2017
Monday, 27 February 2017
On 23 February 2017 a royal decree was published in the Belgian Official Gazette that abolishes the obligation for VAT taxable persons submitting quarterly VAT returns to make advance payments.…
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T/A economics: Painting a new story...
Monday, 13 February 2017
... as the BeNeLux alternative for transfer pricing and valuation services, yet with a distinct approach. T/A economics is proud to announce its launch. T/A economics is a joint venture between…
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Luxembourg introduces new rules applicable to intra-group financing companies
Tuesday, 03 January 2017
1. Introduction The Luxembourg direct tax authorities issued on 27 December 2016 new guidelines by means of the issuance of Circular L.I.R. no. 56/1 – 56bis/1 (hereinafter the “Circular”) which…
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Commission proposes new measures to modernize VAT for cross-border B2C e-commerce
Thursday, 22 December 2016
On 1 December 2016, the European Commission has proposed various legislative changes to improve the current VAT rules on e-commerce1.
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Advocate General ECJ: Fairness Tax contrary to art. 4 Parent-Subsidiary Directive
Monday, 12 December 2016
In a case pending before the European Court of Justice, the Court has been asked to determine whether the Belgian “Fairness Tax” is compatible with the freedom of establishment and…
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The new Belgian REIF - Ready for 'take-off'
Thursday, 08 December 2016
The Royal Decree containing the regulatory framework for the new Belgian Real Estate Investment Fund (“REIF”) has finally been published in the Belgian Official Gazette. Belgian and international real estate…
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Does the finance structure of your real estate investments need to be reviewed?
Thursday, 08 December 2016
Unfortunately, there is as yet no final agreement on a major reform of the Belgian corporate income tax system. However, increasing numbers of tax measures do not require an agreement…
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Permanent establishments: recent developments
Thursday, 03 November 2016
The notion of permanent establishment (‘PE’) and the attribution of profits to a PE continue to develop at an ever-increasing pace. Enterprises engaged in cross-border activities should keep a close…
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Netherlands: proposals on cooperatives and dividend withholding tax
Friday, 28 October 2016
On the third Tuesday of September 2016, which is traditionally Budget Day in the Netherlands, the Deputy Minister of Finance sent a letter to the Dutch Parliament containing proposed changes…
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Luxembourg: VAT on directors' fees
Wednesday, 26 October 2016
On 30 September 2016, the Luxembourg VAT Administration published the much awaited circular-letter on the VAT treatment of company directors (circular-letter 781).
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New tax treaty between Belgium and Japan may stimulate cross-border investments
Tuesday, 25 October 2016
A new tax treaty between Belgium and Japan was signed on 12 October 2016. This treaty, once it becomes applicable, will significantly increase cross-border business opportunities for individuals and corporations…
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Luxembourg: VAT on director fees
Friday, 07 October 2016
On 30 September 2016, the Luxembourg VAT Administration published the much awaited circular-letter on the VAT treatment of company directors (circular-letter 781). This circular-letter is the first official comment by…
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Belgium applies VAT exemption for management of alternative collective investment funds
Thursday, 25 August 2016
The Belgian VAT exemption for the management of investment funds has recently changed following the introduction of the new Belgian Real Estate Investment Trust (B-REIT). However, this change goes further…
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2017 Luxembourg Tax Reform | Draft law
Monday, 08 August 2016
On 26 July 2016 the Luxembourg Government submitted the draft law no. 7020 to the Luxembourg Parliament. The draft law includes a number of direct and indirect tax measures, most…
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