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Cross-border telework: increase of social security threshold to 49%

Wednesday, 10 May 2023

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…


Key Figures in Belgian Estate and Income Tax 2023

Tuesday, 09 May 2023

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…


The recent tax and social security reforms on copyright income: what employers need to know

Wednesday, 03 May 2023

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…


ICLG Private Client Laws and Regulations Belgium 2023

Thursday, 30 March 2023

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…


Are the tax authorities ‘partying with you on stage’?

Monday, 13 March 2023

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.


Amendments to Hong Kong tax regime not sufficient? Update of the EU list on non-cooperative jurisdictions

Tuesday, 21 February 2023

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…


Luxembourg double tax treaties update : UK, France and Germany

Monday, 13 February 2023

On 20 January 2023, the Luxembourg Council of Government took two different important decisions.  


Christophe Dillen joins the partners of Tiberghien

Tuesday, 31 January 2023

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…


ATAD 3 and more: a brief update

Tuesday, 31 January 2023

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…


An informal gift by way of bank transfer in cross-border context: points of interest

Thursday, 26 January 2023

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…


Pillar Two/IFRS Newsflash: IASB consultation on IAS 12 amendements for Pillar Two

Thursday, 12 January 2023

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…


Belgian expat tax regime now extended to foreign non-profit organisations

Tuesday, 10 January 2023

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…


Fiscal Federalism in the EU. A Dynamic Process With Multiple Dimensions

Tuesday, 03 January 2023

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…


Pillar Two - OECD’s Recently Released Safe Harbours and Penalty Relief Guidance : Solving key issues that MNEs face, or just a drop in the ocean?

Friday, 23 December 2022

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…


Belgium - Luxembourg 34-day rule to be approved before year-end

Tuesday, 20 December 2022

On 31 August 2021, Belgium and Luxembourg signed a protocol increasing the 24-day tolerance to 34 days as from 2022.


Breaking: the EU’s Pillar Two Directive received required unanimous support

Tuesday, 13 December 2022

As mentioned in a previous newsflash, the EU Council published a slightly revised draft of the Pillar Two Directive on 25 November 2022. This was done in an attempt to…


Partial VAT deduction applying to the real use method: major changes from 1 January 2023

Tuesday, 13 December 2022

Existing cases: notification required by 30 June 2023 at the latest!


International Tax Update: The rise of the interest rate and the impact on valuations and transfer pricing

Wednesday, 07 December 2022

Behold, the era of free money is no more. This might be hard to digest for governments, companies and investors alike. After an extensive period of record-low interest rates and…


Newsflash: EU Council publishes updated draft Directive on global minimum taxation (Pillar Two) in light of next ECOFIN meeting of 6 December

Friday, 02 December 2022

Last year, the European Commission published, as a Christmas present, a proposal for a Directive on ensuring a global minimum level of taxation for multinational enterprise groups and large-scale domestic…


Luxembourg: interest free loan reclassified into equity – decision Administrative Tribunal

Thursday, 01 December 2022

In the judgement n°44902 dated 23 September 2022, the Tribunal Administrative (the “Tribunal”) requalified an interest free loan granted by a parent company to its subsidiary into equity on the…


European Court overturns public access to UBO register

Friday, 25 November 2022

In its judgment of 22 November 2022 (C37/20 & C/601/20), the European Court of Justice had to consider the compatibility of the UBO register and the fundamental rights to respect…


Credit of foreign inheritance tax on movable property: the Flemish legislator amends, or not quite?

Wednesday, 16 November 2022

The distinction between movable and immovable property for the credit of foreign inheritance tax is contrary to the constitutional principle of equality. This was decided by the Constitutional Court in…


UPDATE: Morocco postpones exchange of financial information, Belgian tax authorities eagerly investigate Turkish bank information

Thursday, 03 November 2022

Morocco has still not conducted a CRS exchange as of 30 September 2022. Morocco has announced a short delay due to technical and legislative reasons. It is expected that Morocco…


Luxembourg draft Budget Law 2023 announces several new tax measures

Wednesday, 02 November 2022

On 12 October 2022, the Luxembourg Minister of Finance Yuriko Backes has filed the draft budget law for 2023 (the “Draft Law”) with the Chamber of Deputies. In a difficult…


Breaking News - Constitutional Court’s decision on the annual tax on securities accounts (ATSA)

Thursday, 27 October 2022

This afternoon, the Belgian Constitutional Court has delivered its long-awaited judgment on the constitutionality of the annual tax on securities accounts introduced by the Act of February 17, 2021.


EU Court of Justice ruling on Belgian participation exemption regime in case of merger (DBI-aftrek/Régime RDT)

Wednesday, 26 October 2022

On October 20, 2022, the European Court of Justice (ECJ) delivered a ruling on the compatibility with the Parent-Subsidiary Directive of certain aspects of the Belgian participation exemption regime (“dividend…


Additional taxes for the Belgian financial sector

Friday, 21 October 2022

A little-publicized budgetary measure involving additional taxes for the financial sector could lead to a snowball of additional taxes on Belgian regulated investment companies.


International Tax Update: Arbitration procedures between the Netherlands and Luxembourg can take off

Thursday, 20 October 2022

The so-called multilateral instrument (‘MLI’) provides for a simultaneous modification of all double tax treaties which are considered by both signatories of the MLI as a ‘covered agreement’. The MLI…

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International Tax Update: BAPA manual published by the OECD

Monday, 10 October 2022

The OECD Forum on Tax Administration has published on 28 September 2022 a manual on Bilateral Advance Pricing Arrangements, namely the Bilateral Advance Pricing Arrangement Manual (“BAPAM” or “Manual”). This BAPAM…

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