On February 15th, the Belgian accounting standards boards (Comissie voor Boekhoudkundige normen – hereafter “CBN”) published additional guidance with respect to mergers and demergers of companies having negative net asset…
Recently, the concept ‘fixed establishment’(‘FE’) for VAT purposes is the subject of many discussions and it seems that the saga will continue. In a judgement of 22 October 2021, the…
On December 22, 2021, the European Commission published a potentially far-reaching proposal for a new directive. The aim of this proposal is to "tackle the misuse of undertakings that do…
A new expat tax regime for incoming executives and researchers entered into force in Belgium on 1 January 2022. Considering the change in the special tax regime’s scope, conditions and…
Yesterday, 31 January 2022, the UAE Ministry of Finance announced the introduction of a federal corporate income tax (‘CIT’). For financial years starting on or after 1 July 2023, UAE…
ELTIF introduced mid 2021 By the Belgian Act containing various provisions of 27 June 2021 (Belgian Official Gazette 9 July 2021), the regime of a European Long Term Investment Fund…
The OECD published today the successor of the July 2017 edition of the Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (“OECD TP Guidelines”). This 'January 2022' edition of…
On 13 December 2021, the OECD updated several country profiles and added profiles for three new countries (a second batch further to the first batch that was released in August…
Did you or your company recently have to deal with a transfer pricing audit? If not, there is a good chance you will be faced with one soon. The number…
To cover the large financial spending caused by the Covid-19 pandemic, countries worldwide are forced to take substantial fiscal actions. This contribution takes a closer look at the extent to…
How the MLI enters into effect between Belgium and the Netherlands, but is not opposable to the Belgian taxpayer (yet) In our previous international tax update we already indicated that…
Withholding tax exemption under EU law In the event of an allocation or payment of interest from a Belgian company to a company incorporated under foreign law, a withholding tax…
Somewhat unexpected and until today largely undetected, Belgium and the Netherlands have deposited notifications to the OECD Secretariat, with the intention of bringing their current double tax treaty under the…
A recent VAT administrative circular letter, implementing EU VAT case law, has tightened the conditions for applying the VAT exemption for services in connection with the export of goods out…
On 11 November 2021, the European Parliament approved the implementation of what is commonly referred to as the public country-by-country reporting (CbCR) Directive.1 This formal approval of the European Parliament came…
On 9 November 2021, after long discussions and negotiations, France and Belgium signed a new Double Tax Convention (‘DTC’). Once the ratification process will be completed in both countries, this…
On 8 October 2021, the already historical agreement about Pillars I and II was reached between 136 member jurisdictions of the OECD/G20 Inclusive Framework. A part of the overall agreement…
German Real Estate Transfer Tax Rules for share deals As in Belgium, German Real Estate Transfer Tax (“RETT”) is triggered by the notarization of a direct real estate purchase. The…
With its Law of February 17, 2021, Belgium introduced a new annual tax on securities accounts (hereafter: “ATSA”), which has replaced the previously annulled tax on securities accounts that the…
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…
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.…
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…
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…
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.…
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…
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…
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…