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International tax update: UAE introduces corporate income tax
Tuesday, 01 February 2022
Yesterday, 31 January 2022, the UAE Ministry of Finance announced the introduction of a federal corporate income tax (‘CIT’). For financial years starting on or after 1 July 2023, UAE…
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The Belgian ELTIF: ready for launch in 2022?
Thursday, 27 January 2022
ELTIF introduced mid 2021 By the Belgian Act containing various provisions of 27 June 2021 (Belgian Official Gazette 9 July 2021), the regime of a European Long Term Investment Fund…
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International Tax Update: 'New' 2022 OECD Transfer Pricing Guidelines: Bundling of earlier guidance
Thursday, 20 January 2022
The OECD published today the successor of the July 2017 edition of the Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (“OECD TP Guidelines”). This 'January 2022' edition of…
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International Tax Update: Belgian transfer pricing country profile at OECD.org refers to the latest Belgian transfer pricing circular letter, whereas arguably the OECD Transfer Pricing Guidelines are more relevant as a source of reference
Friday, 14 January 2022
On 13 December 2021, the OECD updated several country profiles and added profiles for three new countries (a second batch further to the first batch that was released in August…
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The ultimate guide to get you through a transfer pricing audit
Friday, 07 January 2022
Did you or your company recently have to deal with a transfer pricing audit? If not, there is a good chance you will be faced with one soon. The number…
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International Tax Update: Dear tax administration: what you don’t publish can be used against you – but not against the taxpayer
Friday, 24 December 2021
How the MLI enters into effect between Belgium and the Netherlands, but is not opposable to the Belgian taxpayer (yet) In our previous international tax update we already indicated that…
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International Tax Update: Tax treaties extend withholding tax benefits beyond the scope of European Directives - the example of interest paid to French société par actions simplifiée 'SAS'
Monday, 13 December 2021
Withholding tax exemption under EU law In the event of an allocation or payment of interest from a Belgian company to a company incorporated under foreign law, a withholding tax…
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International Tax Update: MLI to cover the Belgium – Netherlands tax treaty as of 1 January 2022
Friday, 10 December 2021
Somewhat unexpected and until today largely undetected, Belgium and the Netherlands have deposited notifications to the OECD Secretariat, with the intention of bringing their current double tax treaty under the…
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VAT exemptions for logistics services and (sea)port activities: watch out for the VAT officer!
Wednesday, 24 November 2021
A recent VAT administrative circular letter, implementing EU VAT case law, has tightened the conditions for applying the VAT exemption for services in connection with the export of goods out…
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International Tax Update: Important changes to the Belgian special taxation regime for foreign executives
Wednesday, 24 November 2021
The Belgian government agreed in the recent budgetary agreement on important changes for foreign executives falling under the special taxation regime.
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International Tax Update: Public Country-by-Country Reporting takes last hurdle in legislation process
Wednesday, 17 November 2021
On 11 November 2021, the European Parliament approved the implementation of what is commonly referred to as the public country-by-country reporting (CbCR) Directive.1 This formal approval of the European Parliament came…
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Breaking news : Belgium and France signed a new Double Tax Convention
Wednesday, 10 November 2021
On 9 November 2021, after long discussions and negotiations, France and Belgium signed a new Double Tax Convention (‘DTC’). Once the ratification process will be completed in both countries, this…
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International Tax Update: Digital Service Tax: Dead and done with?
Wednesday, 27 October 2021
On 8 October 2021, the already historical agreement about Pillars I and II was reached between 136 member jurisdictions of the OECD/G20 Inclusive Framework. A part of the overall agreement…
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International Tax Update: Recent tax developments in Germany
Tuesday, 05 October 2021
German Real Estate Transfer Tax Rules for share deals As in Belgium, German Real Estate Transfer Tax (“RETT”) is triggered by the notarization of a direct real estate purchase. The…
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Belgian Annual Tax on Securities Accounts challenged before Constitutional Court: annulment appeal is no suspension
Thursday, 23 September 2021
With its Law of February 17, 2021, Belgium introduced a new annual tax on securities accounts (hereafter: “ATSA”), which has replaced the previously annulled tax on securities accounts that the…
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International Tax update: Belgian Transfer Pricing Court Case
Thursday, 16 September 2021
In a recently published decision dd. 8 June 2021 of the Court of Appeal of Ghent relating to transfer pricing (nr. 2016/AR/455), the Court decided in favor of the taxpayer.…
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International Tax update: Excess profit rulings: Victory for the European Commission?
Friday, 17 September 2021
On 16 September 2021, the Court of Justice of the European Union dealt for the first time with the Belgian excess profit rulings. The Court ruled (in contrast to the…
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International Tax update: The Belgium - Luxembourg 24 day-rule becomes the 34 day-rule
Tuesday, 07 September 2021
The salary of a Belgian tax resident relating to days performed in Luxembourg is generally taxable in Luxembourg according to the Belgium-Luxembourg double tax treaty. The days worked outside of…
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Luxembourg Newsflash: New administrative circular sets guidelines for the imposition of tax fines
Monday, 09 August 2021
The 2017 tax reform significantly strengthened the power of the Direct Tax Authorities to impose tax fines on taxpayers found in infringement of their tax obligations. In this scope, the…
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VAT and e-commerce: Belgium implements new rules on importer of record
Friday, 09 July 2021
Following the adoption of the law implementing the new e-commerce VAT rules in Belgium, a Royal Decree has been published on 29 June 2021, amending several earlier Royal Decrees on…
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