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International Tax update: Excess profit rulings: Victory for the European Commission?
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…News
International Tax update: Belgian Transfer Pricing Court Case
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.…News
International Tax update: The Belgium - Luxembourg 24 day-rule becomes the 34 day-rule
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…News
Luxembourg Newsflash: New administrative circular sets guidelines for the imposition of tax fines
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…News
VAT registration with a fiscal representative in Belgium: new guarantee rules will create more burdens for foreign taxpayers
A recently adopted amendment to Royal Decree nr. 31 will alter the guarantee requirements for a Belgian VAT registration of a foreign taxpayer with the appointment of a fiscal representative.…News
VAT and e-commerce: Belgium implements new rules on importer of record
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…News
Asia is stepping up its tax game: faceless tax audits, major tax reforms and much more
The Asia-Pacific Tour of the Tiberghien World Tour brought to light a number of interesting developments in the innovative and changing tax landscape in Asia. Not only are Asian countries…News
Luxembourg tax authorities update their Circular on interest limitation rules for members of a consolidated group
On June 2nd, 2021, the Luxembourg tax authorities reissued their Circular n°168bis/1 dated January 8th, 2021 on the interest limitation rules governed by article 168bis of Luxembourg Income Tax Law…News
International Tax update: Evolving towards more OECD-compliancy: the times are changing in the Middle East
The Middle Eastern leg of the Tiberghien world tour showed some interesting developments in tax legislation of this region. These (expected) changes will undoubtedly have a big impact on MNE’s…News
Can tax related and IT services benefit from the VAT exemption for the management of special investment funds? The European Court of Justice says yes.
The Court of Justice of the European Union (ECJ) ruled in the joined cases K (C-58/20) and DBKAG (C-59/20) that the management of tax related responsibilities and the supply of…News
International Tax update: Mutual tax agreements mitigating the impact of Covid-19 telework for internationally active employees extended until September 2021
Due to the Covid-19 pandemic, most employees have worked from home for a large number of days from March 2020 onwards. As the taxation of salaries and the applicable social security…News
Teleworking due to COVID 19: Luxembourg mutual tax agreements with Belgium, France and Germany still in force.
UPDATE Teleworking due to COVID 19: Luxembourg mutual agreement with Germany will remain in force at least until the end of 2021 A new agreement has been signed between Germany…News
Taxation of (ex-)partners and children
Some points of attention for spouses, legal cohabitants and separated parents You are separated or in the process of separating and are wondering how you will be taxed and who…News
International Tax update: EU Agreement with regard to Public country-by-country reporting for certain undertakings
On 1 June 2021 the EU Council negotiators and the negotiation team of the European Parliament reached a provisional political agreement on a proposed directive on the disclosure of income tax…News
International Tax update: Biden’s Green Book and the Old Continent
Last week the US Treasury Department released the long-awaited “Green Book”, explaining the tax proposals of the Biden Administration. The final version is shorter and less detailed than expected. Nevertheless,…News
International Tax update: The ECJ further defines the notion of a VAT fixed establishment
The Court of Justice of the European Union (ECJ) ruled in the Titanium case (C‑931/19) that own staff is required for a (sales) VAT fixed establishment (FE) to be present…News
Tax Treaty Making in Belgium. Well regulated?
The fact that Belgium has a wide network of double taxation conventions (‘tax treaties’) is positive for the Belgian economy and Belgian taxpayers. Each new tax treaty is welcomed. But…News
Tiberghien colleague Rik Smet receives honorable mention for prestigious award
In June last year our colleague Rik Smet successfully defended his doctoral thesis on tax treaty making in federations.News
International Tax update: Tiberghien World Tour PART I - AMERICAS
Last week, on 27 May 2021, we organized the first of four free interactive web events of our Tiberghien World Tour 2021. In these events, local experts of our WTS…News
International Tax update: European Commission’s view on business taxation in the 21th century
On May 18, 2021, the European Commission announced its vision on “Business Taxation for the 21st century”. It did so by means of a Communication to the European Parliament and…News
EU General Court judgements: Engie received illegal state aid, Amazon did not
On 12 May 2021, the EU General Court delivered two judgements relating to appeals made against the EU Commission’s decisions taken back in 2017 and 2018. In these decisions, the…News
International Tax update: Unexpected tax exposure for companies due to home office abroad?
As a result of the COVID-19 crisis, many cross-border workers are working from their home office, which is not necessarily located in the same country as their employer’ office. Also…News
New e-commerce VAT rules as from 1 July 2021: Watch out for double taxation on e-sales of imported goods with a value exceeding € 150
As from 1 July 2021, the e-commerce VAT package enters into force. As a result, online sales to private individuals will generally be subject to VAT in the EU Member…News
The CSSF has published a circular on teleworking for supervised entities in a non-pandemic situation
On 9 April 2021, the Luxembourg's financial sector supervisory authority (Commission de Surveillance du Secteur Financier - "CSSF") published CSSF Circular 21/769 on “Governance and security requirements for Supervised Entities…Events
17 June 2021 | 9 a.m. - 1 p.m. | HOPIN platform
Tiberghien World Tour: Asia-Pacific (web event)
Speaker: Koen Morbée, Andy Neuteleers, Stijn Vastmans, Jurgen Gevers
Events
10 June 2021 | 10 a.m. - 2 p.m. | HOPIN platform
Tiberghien World Tour: Middle East & Africa (web event)
Speaker: Koen Morbée, Andy Neuteleers, Stijn Vastmans, Tine Slaedts
Events
27 May 2021 | 4 p.m. - 8 p.m. | HOPIN platform
Tiberghien World Tour: Americas (web event)
Speaker: Koen Morbée, Robin Minjauw, Andy Neuteleers, Rik Smet
News
Tiberghien International Tax update: Wake-up call: European Parliament demands EU to take appropriate action in taxing the digital economy
On April 29th the European Parliament (“EP”) adopted its resolution “on digital taxation: OECD negotiations, tax residency of digital companies and a possible European Digital Tax”. The EP again reiterates…News
Tiberghien International Tax update: New withholding tax rules on UK sourced interest and royalty payments as from 1 June 2021
With the expiry of the Brexit transition period as of 1 January 2021, the United Kingdom is no longer bound by EU law, including the Interest and Royalties Directive (hereafter…News
An active UN adopts new UN model treaty provision regarding income from automated digital services
The UN has recently been very active in the area of taxation. On 20 April, the UN Committee of Experts on International Cooperation in Tax Matters agreed to adopting a…Subscribe
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