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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,…
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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.
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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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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…