On 7 March 2019, the European Commission (the “EC”) announced that it will open an investigation into tax rulings issued by the Luxembourg tax authorities to Huhtalux S.à r.l. (“Huhtalux”),…
In its highly anticipated judgments of 26 February 2019, the ECJ took a decision in the so-called “beneficial ownership”- cases. These cases relate to the application of the interest-royalty directive…
In the past Belgian entities could obtain an advance ruling from the Belgian tax authorities, confirming that profits regarded as being ‘excess’, in that they exceeded the profit that would…
As announced in our previous articles (UBO register very close to be introduced in Luxembourg ! and Luxembourg UBO Register accessible to all !), Luxembourg will implement a register which…
In order to service an increasing demand of specific expertise in the field of customs and excise duties, Tiberghien reinforces its Indirect Taxes practice group. With almost 20 years of…
Brexit will have a significant impact on all companies doing business with the UK. In particular, the consequences for customs and VAT will be tremendous. As recently emphasised by Minister…
Introduction The Belgian Court of Cassation has ruled on 25 January 2018 on the application of art. 23, § 1, a (“methods for elimination of double taxation”) of the Belgian-Dutchdouble…
An expert panel of the Pro League (the organization representing the interests of all professional Belgian football clubs) appointed by the latter and presided by Belgian minister of State, Melchior…
An international transfer of a football player from one professional club to another may cause various financial streams with specific tax ramifications with sometimes doubtful solutions. The purpose of this…
On 17 October 2018 the Court of Justice of the European Union (‘CJEU’) delivered its ruling in the Ryanair case (C-249/17). This decision resolves the issue of input VAT recovery…
The Belgian government is contemplating to introduce a more general reporting and tax withholding obligation for Belgian companies/subsidiaries when benefits (such as free shares or shares at reduced price) are…
On 20 March 2018 the Grand Chamber of the EUCJ delivered three rulings on the extent to which the principle of ne bis in idem permits Member States from imposing…
Previously, we informed you about the introduction of the Belgian UBO register (see this link). This UBO register is a centralised database (organised on a European level) through which companies, associations,…
The optional regime for a VAT taxable rent (for a detailed overview of this new regime, see link) has been approved by the Belgian Chamber of Representatives on 4 October…
On 2 October 2018 a much-anticipated ECOFIN meeting was held in Luxembourg. The EU Ministers of Finance reached an agreement on quick fixes, the generalised reverse charge mechanism and the…
The Belgian authorities have adopted a new policy for imposing penalties in VAT matters. Traditionally the Belgian authorities have applied a strict policy for imposing penalties. Each VAT error is…
On 10 July 2018, government amendments were proposed to the draft bill introducing the UBO register in Luxembourg (the “Register”). These amendments are in line with the provisions of Directive…
On July 26, 2018 the Luxembourg tax authorities issued Circular L.I.R. n°14/5 - 99/3 - 99bis/3 on the Luxembourg tax treatment of transactions involving cryptocurrencies (the “Circular”).The main aspects of…
For prior coverage after the introduction of the bill of law dated 16 April 2018 (the “Bill”), we refer to our newsletter of 3 May 2018. As indicated in our…
In March 2018, the Belgian government reached a final agreement on the introduction of an optional system for VAT and immovable rent. At that time, the main characteristics of the…