News
VAT deduction and active holdings: EU case law widens the scope
On July 5, 2018 the Court of Justice of the European Union delivered a new and welcome judgment about input VAT recovery by holding companies (ECJ, Marle Participations SARL, C-320/17,…
News
Luxembourg draft law to implement the Anti-Tax Avoidance Directive (ATAD)
On June 19th, 2018 was released the draft law (the “Draft Law”) implementing, among other provisions inspired by BEPS, the EU Anti-Tax Avoidance Directive (“ATAD” or the “Directive”). ATAD was…
News
NEW reporting obligation for cross-border arrangements – European Directive of 25 May 2018 entered into force on 25 June 2018.
On 25 May 2018, the Council Directive amending Directive 2011/16/EU concerning the mandatory automatic exchange of information in the field of taxation for reportable cross-border arrangements was approved. From 1…
News
Private Privak (Pricaf) 3.0 – an update
The Private Privak (Pricaf) has been amended a third time, based on the needs of the private equity sector. This reform eliminates major constraints which limited the success of the…
News
NEW reporting obligation for cross-border arrangements – Council Directive approved 25 May 2018
Today, Friday 25 May 2018, has seen the approval of the Council Directive amending Directive 2011/16/EU concerning the mandatory automatic exchange of information in the field of taxation for reportable…
Events
Tax Treaty Case Law around the Globe 2018
News
Luxembourg VAT Grouping On Its Way !
On 16 April 2018, a bill of law (no. 7278, the “Bill”) has been presented to Luxembourg Parliament which aims at introducing in Luxembourg a grouping regime for Luxembourg value…
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New Luxembourg intellectual property regime in force
Luxembourg new tax regime designed to increase intellectual property (“IP”) developments has entered into force in April 2018 and is effective as of 1 January 2018. The new regime (the…
News
France and Luxembourg sign revised double tax treaty
On 20 March 2018, a new double tax treaty was signed between France and Luxembourg (hereinafter the "DTT"). It will replace the current version of the treaty dated 1 April…
Events
ABA's Tax Planning Strategies U.S. and Europe Conference
News
Corporate Tax Reform
A recent reform has reshaped the corporate income tax rules in various key areas, thus creating new tax benefits for Belgian companies, but also introducing new compensating measures to balance…
News
New position of the Belgian social security authorities on determining the applicable social security regime (EU REGULATION 883/2004)
Belgium now applies the principle of “requalification”. In the context of international employment situations, the EU Regulation 883/2004 determines which social security legislation is applicable to people working simultaneously in…
Events
Tax Executives Institute 68th Midyear Conference
News
New EU transparency rules for intermediaries involved in cross border tax planning
On 13 March, the EU Member States reached a political agreement on the European Commission’s proposal dated June 2017 aiming at strengthening tax transparency by the introduction of a mandatory…
News
PRESS RELEASE - WTS Global creates cutting-edge European Tax Law Centre in Brussels
Brussels, February 20, 2018 - WTS Global, the leading global tax practice, establishes its cutting-edge European Tax Lax Centre in Brussels under the leadership of Tiberghien
Events
Indirect Tax Forum
News
UBO registers further tightened throughout the EU !
Whilst the Luxembourg law proposal of 6 December 2017, which introduced the UBO register imposed under the fourth EU anti-money laundering directive (2015/849/EC, the “Fourth Directive”) into Luxembourg domestic law, is still…
News
UBO register very close to be introduced in Luxembourg !
Following the adoption of the fourth EU anti-money laundering directive (2015/849/EC, the “Directive”) which aim is to prevent money laundering and terrorism financing by means of, inter alia, introducing central…
Events
New Perspectives on Fiscal State Aid: Legitimacy and Effectiveness of Fiscal State Aid Control
News
Ecofin agreement on new rules for e-commerce and e-books
This article briefly describes the new rules. Together with the higher focus of the VAT authorities on VAT and e-commerce, this evolution makes clear that a correct VAT compliance is…
News
US Senate approves tax bill
On Saturday 2 December, the Senate voted 51 to 49 to pass an amended version of the tax reform bill.
News
US Tax reform bill: Tax Cuts and Jobs Acts
17/11/2017 - On November 2, the House Republican's tax reform bill – the Tax Cuts and Jobs Act – was released. This bill is 429 pages and should provide for…
Publications
Belgium introduces horizontal supervision
In the ongoing fight against tax fraud, the Belgian federal government intends to implement a new approach for tax audits. In the future, tax inspectors will no longer perform day-to-day…
News
Participation exemption for dividends received by parent companies: 100% exempt
In the framework of the expected corporate income tax reform (further to the agreement reached at government level last summer), the Belgian government intends increasing the participation exemption (dividend received…
News
Christophe Coudron appointed as National Branch Reporter at IFA Congress 2019
The Board of the Belgian IFA Branch has appointed Christophe Coudron as National Branch Reporter on the topic 'Investment Funds' at the IFA Congress in London in 2019. Christophe continues…
Publications
Towards a More Coordinated Approach of the Relation Between the Taxpayer and Tax Administrations: The European Taxpayers’ Code
In its Communication of 27 June 2012 the European Commission stated that an increase in efficiency and effectiveness of the administration of tax collection is crucial in fighting tax fraud and evasion. As…
Events
Wealth+ Private Banking & Wealth Management Summit
Publications
WTS Transfer Pricing Newsletter October 2017
The WTS TP newsletter summarizes new developments in the field of TP for 10 countries and has been prepared by local TP experts within the global WTS-network. Jean-Luc Dascotte, Michiel Boeren and…
News
Court of Justice restricts the VAT exemption for cost-sharing associations: significant impact on the financial, insurance and real estate sectors
26/09/2017 - On 21 September 2017 the Court of Justice of the European Union drastically restricted the VAT exemption for cost-sharing associations in a number of controversial judgments. The bank…
News
VAT Revolution in the Real Estate Sector: Belgium to introduce optional VAT regime for immovable letting
17-08-2017 – On 26 July 2017, the Belgian federal government reached an agreement on the principles of the state budget for the coming year. In addition to a number of…
Events
BVA's President Meeting
News
The Belgian government reaches an agreement on corporate income tax reform
On 26 July 2017, the federal government reached an important agreement on corporate income tax reform.
Publications
VAT and Directors’ Fees in the Benelux
The VAT Directive does not clearly address the question of the VAT treatment of directors’ fees, and recent developments in Dutch, Belgian and Luxembourg VAT legislation have emphasized the lack of harmonization on that question…
Publications
WTS - Assignments in Europe 2017
Tiberghien’s HR Tax Team contributed to the new WTS Brochure on “Assignments in Europe 2017”. In the booklet you will find a brief overview of tax, social security and immigration…
Publications
The broader scope of the Belgian VAT exemption for the management of special investment funds offers opportunities for private equity funds
23-06-2017 - In 2016, the Belgian VAT exemption for the management of investment funds changed following the introduction of new rules for the Belgian Real Estate Investment Trust (B-REIT). However,…
News
Two awards for WTS at ITR European Awards Ceremony
Tiberghien’s partner WTS was distinguished in two areas at this year’s International Tax Review (ITR) European Awards Ceremony, which took place on May 18 in London. WTS Global was honored…
News
ECJ decides on Belgian “Fairness Tax” and French “Contribution Additionnelle”
18-05-2017 - The European Court of Justice decided that both the Belgian “Fairness Tax” and the French “Contribution Additionnelle” are – to a certain extent – incompatible with art. 4…
Events
Adults & Children in Postmodern Societies - International Family Law Conference
Events
International Tax Conference "Growth and Taxes"
News
Tiberghien opens new office in Ghent
09-05-2017 - Tiberghien, the specialist tax law firm with over 80 lawyers and the largest tax practice in Belgium, has opened a new office in Ghent. The new location is…
News
CbCR: Luxembourg implements Directive (EU) 2016/881, what are the lessons at this stage?
26-04-2017 - The process in Luxembourg has been particularly fast, with the entry into force of the new mechanism in domestic law less than 12 months after the adoption of…
News
New Belgian exit tax rules
26-04-2017 - Belgium introduces a deferred payment regime for companies required to pay exit taxes on outbound cross-border relocation of assets, migration or restructuring in line with article 5 of…
News
Belgian register of ultimate beneficiaries (“UBO-register”) is approaching
26-04-2017 - Under Articles 73 to 75 of the draft Bill on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing…
News
The CJEU’s Wereldhave judgment: Dutch investment funds with “Fiscal Investment Institution” status do not fall within the Parent-Subsidiary Directive’s scope
26-04-2017 Facts Two Dutch companies, Wereldhave International and Wereldhave, respectively own 35% and 44% of the Belgian company, Wereldhave Belgium. Both Dutch companies have the “Fiscal Investment Institution” (“fiscale beleggingsinstelling”)…
News
Taxation of pensions paid by Belgian debtors to non-residents: change of rules
26-04-2017 Pensions subject to Belgian non-resident income tax The Belgian Income Tax Code provides, as a basic rule, that occupational pensions paid to non-resident individuals are subject to tax in…
News
Belgium introduces exit tax rules as it implements ATAD
06-04-2017 Belgium introduces a deferred payment regime for companies required to pay exit taxes on the cross-border relocation of assets, migration or restructuring in line with the EU Anti-Tax Avoidance…
News
Tiberghien’s continued growth
03-04-17 In recent years, tax law firm Tiberghien has seen tremendous growth. Now, in addition to this organic growth, the tax lawyers of the law firm Dauginet, will be joining…
Publications
International double taxation in the European Union: comparative guidelines from Switzerland and the United States
27-03-2017 The Court of Justice of the European Union (CJEU) ruled on several occasions that, while international double taxation may hinder the fundamental freedoms guaranteed by European Union (EU) law,…
News
New Belgian Innovation Profits Deduction (“IPD”)
2017-03-14 - After the abolition of the patent income deduction, the Belgian government announced on 2 December 2016 a new tax deduction for innovation profits. In line with the OECD’s recommendations…
News
VAT advance payments for quarterly VAT returns abolished from 1 April 2017
On 23 February 2017 a royal decree was published in the Belgian Official Gazette that abolishes the obligation for VAT taxable persons submitting quarterly VAT returns to make advance payments.…
News
T/A economics: Painting a new story...
... as the BeNeLux alternative for transfer pricing and valuation services, yet with a distinct approach. T/A economics is proud to announce its launch. T/A economics is a joint venture between…
Events
17th Annual Tax Planning Strategies - U.S. and Europe
Events
Symposium: The Belgian Reform of Succession Law from a Comparative Perspective
Publications
Income Taxation of Trusts in Belgium
Trusts do not exist under Belgian civil law. However, trusts governed by foreign law are generally analyzed by applying conflict of law rules. As a result, Belgium will generally recognize…
Events
Seminar STEP: 'Global and European Crossroads : Dutch and Belgian Cross-Border Estate Planning'
News
Luxembourg introduces new rules applicable to intra-group financing companies
1. Introduction The Luxembourg direct tax authorities issued on 27 December 2016 new guidelines by means of the issuance of Circular L.I.R. no. 56/1 – 56bis/1 (hereinafter the “Circular”) which…
