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Navigating the Nuances: The Administrative Court's Interpretation of Loan vs. Equity Characteristics
Thursday, 29 February 2024
On 23 November 2023, in case number 48125C, the Luxembourg Administrative Court overruled a decision rendered by the Administrative Tribunal on 23 September 2022.
News
Tiberghien moves to Tweetorenwijk in Hasselt
Thursday, 22 February 2024
We are proud to announce our new location in the heart of Hasselt. This move represents a significant strengthening of our presence in the region.
News
New Belgium-Netherlands double tax treaty - Permanent establishment provisions amended in line with MLI
Thursday, 15 February 2024
The new double tax treaty between Belgium and the Netherlands will introduce significant changes compared to the current Article 5 on permanent establishments. Due to the positions of Belgium and…
News
(Shareholders of) corporate groups: beware of new CFC and cayman tax rules
Thursday, 08 February 2024
The Belgian legislator adopted new legislation on December 22, 2023, significantly modifying two sets of rules: (i) the CFC rules (“Controlled Foreign Corporation rules”) applicable to Belgian corporate taxpayers and…
Publications
The International Comparative Legal Guide - Private Client 2024
Wednesday, 07 February 2024
The latest edition of the International Comparative Legal Guide – Private Client has just been published! Tiberghien Lawyers Alain Van Geel, Griet Vanden Abeele and Emilie Van Goidsenhoven contributed to…
News
Withholding tax on Dividends, Interests and Royalties under the new Belgian - Dutch double tax treaty - Main changes
Tuesday, 16 January 2024
The withholding tax jurisdiction of the source state is limited to 15% for dividends, as before. Withholding tax may (no longer) be withheld when dividends are paid by subsidiaries to parent companies…
News
European Court of Justice ruling: end of the application of VAT on director fees in Luxembourg
Thursday, 04 January 2024
On December 21, 2023, the European Court of Justice (“ECJ”) issued its long-awaited ruling in the case C288/22 “TP” on the VAT treatment of director fees. From a Luxembourg VAT…
News
CAYMAN TAX 2.1 – sharpened teeth or mere dentures? A first update based on the draft bill as finally submitted to parliament.
Wednesday, 13 December 2023
PREFACE : This newsletter is only a first brief look at yet another very complex draft of cayman tax adjustment. Further analysis is recommended. This is an update of the…
News
Luxembourg minimum net wealth tax provisions declared partly unconstitutional
Tuesday, 12 December 2023
Main takeaways On 10 November 2023, the Luxembourg Constitutional Court ruled that certain provisions of the Luxembourg minimum net wealth tax were contrary to constitutional principle of equality. Pending a…
News
CAYMAN TAX 2.1 – sharpened teeth or mere dentures?
Friday, 03 November 2023
The draft bill approved at the Council of Ministers meeting on Friday, Oct. 27, 2023, proposes a whole number of changes to the cayman tax to ensure - in its…
News
Two new partners join the ranks
Tuesday, 24 October 2023
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…
Tiberghien Tax Law Manual
