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Fiscal Federalism in the EU. A Dynamic Process With Multiple Dimensions

Tuesday, 03 January 2023
In 2021 the European Association of Tax Law Professors held its annual conference on ‘History and Taxation’. One topic dealt with Fiscal Federalism. This concept refers to the study of…

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…

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.

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…

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!

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…

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…

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…

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…

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…

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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