News
Cayman tax remains applicable under new Dutch-Belgian double taxation treaty
The interaction of the Belgian cayman tax with the various double taxation treaties concluded by Belgium has been the subject of discussion in practice for several years. The question now…
News
Accounting reform in Luxembourg - Draft law submitted to parliament
Luxembourg government launched the first step of a reform of the Luxembourg accounting legal framework. The main objective is to consolidate into one single law the Luxembourg accounting rules currently…
News
New double taxation treaty between Belgium and the Netherlands - implications for individual investors
The double taxation treaty between Belgium and the Netherlands, signed on 21 June 2023, will result in certain changes for private investors. The main concerns are the impact on the…
News
Cross-border telework in Luxembourg: ongoing developments
Under the EU social security Framework Agreement, Luxembourg cross-border workers may telework more often from their state of residence without impacting their applicable social security legislation (provided telework represents less…
News
CBAM regulation adopted on 10 May 2023
On 10 May 2023, the Council of the European Union and the European Parliament adopted the new regulation (EU) 2023/956 establishing a carbon border adjustment mechanism (CBAM). CBAM is designed…
News
Breaking - The new double taxation treaty between the Netherlands and Belgium
On 21 June Belgium and the Netherlands signed a new double tax treaty on income taxes. Unlike under the current treaty, the scope of this treaty will be limited to…
News
Brazil’ legislator enacts new transfer pricing law
On 15 June 2023, Brazil published a new law establishing a transfer pricing framework that is aligned with the OECD Transfer Pricing Guidelines (“OECD TPG”). Reforming Brazil’s transfer pricing (“TP”)…
News
Luxembourg tax authorities issue guidance on reverse hybrid rules
On 9 June 2023, the Luxembourg direct tax authority (Administration des contributions directes, the “ACD”) released a 3-page circular – L.I.R n°168quater/1 (“Circular”) in relation to the so-called reverse hybrid…
News
Cross-border telework: increase of social security threshold to 49%
The Administrative Commission for the Coordination of Social Security Systems of the European Union proposed a standard agreement aiming to increase the social security “threshold” for cross-border telework as from…
News
Key Figures in Belgian Estate and Income Tax 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
The recent tax and social security reforms on copyright income: what employers need to know
Following an intense debate, the legislator introduced a new tax scheme applicable to copyright income. Main raison for this initiative is the assumed abuse of the until then beneficial tax…
Publications
ICLG Private Client Laws and Regulations Belgium 2023
Griet Vanden Abeele, Alain Van Geel and Emilie Van Goidesenhoven contributed to the International Comparative Legal Guide (ICLG) - Private Client 2023. This publication covers common issues in private client…
News
Are the tax authorities ‘partying with you on stage’?
Many festivals have announced the first names for spring and summer 2023. We explain below the tax obligations for festival organisers with foreign artists on the bill.
News
Amendments to Hong Kong tax regime not sufficient? Update of the EU list on non-cooperative jurisdictions
Last week, the ECOFIN meeting of the Council of the EU took place, deciding on an update of the list of non-cooperative jurisdictions (the “black list”) and the list of…
News
Luxembourg double tax treaties update : UK, France and Germany
On 20 January 2023, the Luxembourg Council of Government took two different important decisions.
News
Christophe Dillen joins the partners of Tiberghien
Tiberghien continues to grow and evolve to provide its clients with forward-looking services of the highest standard. It is therefore with great pleasure that we announce the appointment as partner…
News
ATAD 3 and more: a brief update
In December last year, the European Parliament published a resolution on the proposal for a Directive laying down the rules to prevent misuse of shell entities for tax purposes (so-called…
News
An informal gift by way of bank transfer in cross-border context: points of interest
The gift by way of bank transfer is a popular technique for making gifts to children or grandchildren. As this article will show, it involves more than simply transferring money…
News
Pillar Two/IFRS Newsflash: IASB consultation on IAS 12 amendements for Pillar Two
On 9 January 2023, the International Accounting Standard Board (IASB) published Exposure Draft ED/2023/01 which contains important proposed amendments to IAS 12, the International Accounting Standard dealing with accounting for…
News
Belgian expat tax regime now extended to foreign non-profit organisations
On 1 January 2022, a new expat tax regime was introduced in Belgium that provides for a favourable income tax (and social security) treatment for employees, directors and researchers recruited…
Publications
Fiscal Federalism in the EU. A Dynamic Process With Multiple Dimensions
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…
News
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?
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…
News
Belgium - Luxembourg 34-day rule to be approved before year-end
On 31 August 2021, Belgium and Luxembourg signed a protocol increasing the 24-day tolerance to 34 days as from 2022.
News
Breaking: the EU’s Pillar Two Directive received required unanimous support
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…
News
Partial VAT deduction applying to the real use method: major changes from 1 January 2023
Existing cases: notification required by 30 June 2023 at the latest!
News
International Tax Update: The rise of the interest rate and the impact on valuations and transfer pricing
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…
News
Newsflash: EU Council publishes updated draft Directive on global minimum taxation (Pillar Two) in light of next ECOFIN meeting of 6 December
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…
News
Luxembourg: interest free loan reclassified into equity – decision Administrative Tribunal
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…
News
European Court overturns public access to UBO register
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…
Tiberghien Tax Law Manual
