As of 12 November 2024, the Luxembourg Business Registers (the “LBR”) will implement a few changes to the filing formalities with the Luxembourg Trade and Companies Register (Registre de Commerce…
The Belgian tax authorities (FPS Finance) announced that from 2 September 2024 multinational enterprises (MNE) and large domestic groups subject to the minimum tax for MNE groups and large domestic…
On 31 July 2024, the Luxembourg Administrative Court applied the specific anti-abuse rule of the Parent-Subsidiary Directive as transposed into the Luxembourg income tax law (PSD SAAR) for the first…
Main takeaways: A Circular L.I.R. n°170/1, 170bis/1, I.C.C n°44, I.Fort. n°55 (“the Circular”) has been issued by the Luxembourg tax authorities on 19 July 2024 bringing some clarifications on the tax…
We are proud to announce that we’ve been shortlisted for the 2024 ITR EMEA Tax Awards in two categories! We’re competing for the award of Tax Law Firm of the…
We are extremely proud to announce that Tiberghien Lawyers have been awarded a 'Band 1' ranking in Private Wealth Law by Chambers for the ninth time in a row! Alain…
On 14 May 2024, the EU Council reached a political agreement on an amended proposal of the Directive on Faster and Safer Relief of Excess Withholding Taxes (FASTER Directive). The…
Many other European and non-European countries preceded Belgium on the e-invoicing topic. This, together with the EU Commission proposal “VAT in the Digital Age” (click here), pushed Belgium to also introduce…
The Belgian Pillar 2 transposition law was recently amended, in part to incorporate the most recent additional OECD Commentary. This law also provides that “Pillar 2 groups” will (have to)…
Main takeaways: On 23 May 2024, the Minister of Finance submitted a draft law No. 8388 with the Luxembourg Parliament (the “Draft Law”) proposing several new tax measures, mainly: Amendment…
The Belgian Estate and Income tax is characterised by continuous changes and the differences between the three regions are becoming more and more pronounced. We would like to help you…
Daan Buylaert and Mona Vera published the article "Belgium: Special income tax regimes for sportspersons and income from the exploitation of image rights" in the March 2024 edition of Sports…
We are extremely proud to announce that Tiberghien Lawyers have been awarded a 'Tier 1' ranking for tax by Legal500 - 2024 edition, that makes 9 times in a row…
Larissa Dewulf, Carolyn Vanthienen and Alexandra Goossens contributed to the 2024 edition of Chambers and Partners Family Law Global Practice Guide. This global law guide is offering comparative analysis from top-ranked…
The UK recently announced important tax reforms in its Spring Budget 2024. The proposed changes are relevant for individuals who are resident but not domiciled in the UK (so-called “non-doms”…
In an earlier article in this series, we already discussed the planned changes in terms of moveable income. Whilst the changes may seem relatively limited at first glance, Dutch residents…
On 23 November 2023, in case number 48125C, the Luxembourg Administrative Court overruled a decision rendered by the Administrative Tribunal on 23 September 2022.
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…
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…
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…
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…
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…
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…
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…
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…
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…
BEFIT stands for “Business in Europe: Framework for Income Taxation” and is the object of a draft EU directive proposed by the European Commission on 12 September 2023 (the “Draft…
On 4 October 2023, the law of 18 September 2023 was officially published in the Memorial (the Luxembourg official gazette), so that the new tax treaty between Luxembourg and the…
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…
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…
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…
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…
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…
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…
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”)…
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…
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…
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…
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…
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…
Dominique De Bie & Carolyn Vanthienen contributed to this year's Chambers and Partners Family Law Global Practice Guide. They provide expert insights on numerous trends & developments in Belgian family law. Be sure…
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.
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…
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…
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…
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…
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…
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…
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…
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…