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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…
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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.
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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…
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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!
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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…
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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…
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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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European Court overturns public access to UBO register
Friday, 25 November 2022
In its judgment of 22 November 2022 (C37/20 & C/601/20), the European Court of Justice had to consider the compatibility of the UBO register and the fundamental rights to respect…
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Credit of foreign inheritance tax on movable property: the Flemish legislator amends, or not quite?
Wednesday, 16 November 2022
The distinction between movable and immovable property for the credit of foreign inheritance tax is contrary to the constitutional principle of equality. This was decided by the Constitutional Court in…
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UPDATE: Morocco postpones exchange of financial information, Belgian tax authorities eagerly investigate Turkish bank information
Thursday, 03 November 2022
Morocco has still not conducted a CRS exchange as of 30 September 2022. Morocco has announced a short delay due to technical and legislative reasons. It is expected that Morocco…
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Luxembourg draft Budget Law 2023 announces several new tax measures
Wednesday, 02 November 2022
On 12 October 2022, the Luxembourg Minister of Finance Yuriko Backes has filed the draft budget law for 2023 (the “Draft Law”) with the Chamber of Deputies. In a difficult…
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Breaking News - Constitutional Court’s decision on the annual tax on securities accounts (ATSA)
Thursday, 27 October 2022
This afternoon, the Belgian Constitutional Court has delivered its long-awaited judgment on the constitutionality of the annual tax on securities accounts introduced by the Act of February 17, 2021.
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EU Court of Justice ruling on Belgian participation exemption regime in case of merger (DBI-aftrek/Régime RDT)
Wednesday, 26 October 2022
On October 20, 2022, the European Court of Justice (ECJ) delivered a ruling on the compatibility with the Parent-Subsidiary Directive of certain aspects of the Belgian participation exemption regime (“dividend…
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Additional taxes for the Belgian financial sector
Friday, 21 October 2022
A little-publicized budgetary measure involving additional taxes for the financial sector could lead to a snowball of additional taxes on Belgian regulated investment companies.
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International Tax Update: Arbitration procedures between the Netherlands and Luxembourg can take off
Thursday, 20 October 2022
The so-called multilateral instrument (‘MLI’) provides for a simultaneous modification of all double tax treaties which are considered by both signatories of the MLI as a ‘covered agreement’. The MLI…
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International Tax Update: BAPA manual published by the OECD
Monday, 10 October 2022
The OECD Forum on Tax Administration has published on 28 September 2022 a manual on Bilateral Advance Pricing Arrangements, namely the Bilateral Advance Pricing Arrangement Manual (“BAPAM” or “Manual”). This BAPAM…
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VAT treatment of Director fees in Luxembourg
Tuesday, 27 September 2022
On April 29, 2022, the Luxembourg District Court (“Tribunal d’Arrondissement”) submitted a reference for a preliminary ruling in the case TP vs Administration de l’Enregistrement, des Domaines et la TVA…
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Tiberghien has four new counsels since 1 July 2022
Friday, 15 July 2022
Tiberghien has recently appointed Katrien Bollen, Elisabeth De Nolf, Ahmed El Jilali and Gert Vranckx as counsel, thus building further the firm’s growth and innovation. With these appointments we acknowledge…
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Tiberghien has appointed two new partners
Thursday, 07 July 2022
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…
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International Tax Update: ‘ATAD 3’ Update: (Probably) a little more time to prepare and avoid burdensome compliance obligations for in-scope entities
Wednesday, 29 June 2022
At the end of last year, the European Commission published a proposal for a directive to "tackle the misuse of shell entities for tax purposes" (see our previous newsflash on…
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