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International Tax Update: A proposal for a Directive on debt-equity bias reduction allowance (DEBRA)
Wednesday, 25 May 2022
On 11 May 2022, the European Commission published a proposal for a Directive providing for a debt-equity bias reduction allowance (‘DEBRA’). This directive is part of the Commission’s proposed measures…
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Luxembourg treaty exemption for the Annual Tax on Securities Accounts at risk?
Tuesday, 24 May 2022
The Annual Tax on Securities Accounts (hereafter: "ATSA") is applicable (among other things) to securities accounts held in Belgium, even if they are held by non-Belgian residents/account holder. Both the…
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Will you file your first Belgian non-resident income tax return? Do not forget to register before 1 June 2022!
Tuesday, 10 May 2022
Individuals collecting income in Belgium and who qualify as Belgian tax non-residents, are in principle required to file a Belgian non-resident income tax return. Every single Belgian non-resident must fill…
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BREAKING: circular letter regarding expatriate tax regime has been published
Monday, 09 May 2022
Circular letter published Last week Friday, the Belgian tax administration published a circular letter regarding the reformed expat tax regime for incoming executives and researchers. This extensive letter aims to…
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Key Figures in Belgian Estate and Income Tax 2022
Wednesday, 04 May 2022
The continuing changes in Belgian Estate and Income tax, together with the growing discrepancies between the three Belgian regions, are generating a tangle of regulations that are sometimes hard to…
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Key Figures in Belgian Estate and Income Tax 2023
Tuesday, 09 May 2023
The continuing changes in Belgian Estate and Income tax, together with the growing discrepancies between the three Belgian regions, are generating a tangle of regulations that are sometimes hard to…
News
115 account contributions and Luxembourg parent-subsidiary regime
Wednesday, 04 May 2022
Highlights On 31 March 2022, the Luxembourg Administrative Court of Appeal rendered a decision considering that 115 accounts contributions are not to be included in the acquisition price of the…
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Belgian reporting (tax) obligations for platform operators in anticipation of DAC 7 seem safe from an EU perspective
Wednesday, 04 May 2022
In our newsflash of 2 February 2021 (click here) we informed you that Belgium had anticipated the DAC 7 regulation and had already de facto transposed it into domestic law.…
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International Tax Update: (When) Will transfer pricing in Brazil be more aligned with OECD standards?
Monday, 02 May 2022
On 12 April 2022, the OECD and the Brazilian tax authority (Brazil's Receita Federal (‘RFB’)) met in view of a proposed new transfer pricing system, which would be more aligned…
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Legal cohabitants: Can your ex-partner claim maintenance?
Thursday, 14 April 2022
No maintenance expressly stipulated in the law for legal cohabitants In a judgment of 14 March 2017, the Antwerp Court of Appeal awarded a personal maintenance claim to an ex-partner…
News
International Tax Update: The Belgian tax slip obligation – no longer sanctioned as severely as before
Tuesday, 12 April 2022
Court of Justice decides In a recent judgment, the European Court of Justice addressed the obligation under Belgian law to draw up a summary tax slip for commissions paid and…
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Breaking: Ecofin one member state short of agreement on EU Directive on Pillar Two
Tuesday, 05 April 2022
In today’s Ecofin meeting an agreement was not reached regarding a new compromise text of an EU Directive on the introduction of Pillar Two in the European Union. Where at…
News
International Tax Update: Stay on top of ever-changing local transfer pricing documentation requirements
Thursday, 17 March 2022
The Transfer Pricing documentation landscape is continuously evolving, whereby recently, there has been an increasing tendency of various countries updating and strengthening their transfer pricing documentation requirements. Considering these changes,…
News
Interest limitation rules: Tax authorities adopt favorable position for the Private Equity sector
Friday, 11 March 2022
The Belgian Central Tax Authorities have recently taken an important decision on how the ATAD interest limitation rules must apply in the private equity (PE) sector. According to that decision,…
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CBN guidance on (de)mergers with entities having negative net asset values
Thursday, 10 March 2022
On February 15th, the Belgian accounting standards boards (Comissie voor Boekhoudkundige normen – hereafter “CBN”) published additional guidance with respect to mergers and demergers of companies having negative net asset…
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International Tax update: Fixed establishment through an affiliate company in Belgium? The Court of Appeal of Liège affirms.
Wednesday, 09 March 2022
Recently, the concept ‘fixed establishment’(‘FE’) for VAT purposes is the subject of many discussions and it seems that the saga will continue. In a judgement of 22 October 2021, the…
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Non-compete payment upon the ending of an international career... Taxation in the residence state?
Thursday, 24 February 2022
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International Tax Update: Expense allowances granted under the new expat tax regime are exempted from social security contributions
Friday, 11 February 2022
A new special tax regime for incoming executives and researchers entered into force in Belgium on 1 January 2022.
News
Proposal for new European directive: the end of entities with little substance?
Thursday, 10 February 2022
On December 22, 2021, the European Commission published a potentially far-reaching proposal for a new directive. The aim of this proposal is to "tackle the misuse of undertakings that do…
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New Belgian special expat tax regime – who’s in?
Wednesday, 09 February 2022
A new expat tax regime for incoming executives and researchers entered into force in Belgium on 1 January 2022. Considering the change in the special tax regime’s scope, conditions and…
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