News
Covid-19 Telework: how to mitigate the fiscal impact?
Due to the Covid-19 government measures, most employees work mainly from their home offices from March 2020 onwards.
Publications
Overview of Digital Platform Reporting Obligations in the EU
After our publication on Belgium’s digital platforms reporting obligations (which you may read here), the WTS Global Digital Tax Law Center has analyzed whether other EU Member States have implemented…
News
Real estate abroad - fulfil your legal obligations in time!
On 11 February 2021, a draft bill was approved by the Belgian parliament amending the tax treatment of real estate located abroad. With this bill, the Belgian legislator aims to…
News
VAT on making cars available to employees: a headache ahead for cross border employers?
On February 11, 2021, the Luxembourg VAT authorities issued a circular with respect to the treatment applicable to making cars available to employees. The Circular offers clarifications upon the judgment…
News
Further clarifications on the exemption introduced for bonuses granted to employees
The 2021 budget law dated 19 December 2020 (the “Law”) added a §13a to article 115 of the Luxembourg Income Tax Law (“LITL”). This measure introduces a new tax regime…
News
Constitutional Court questions the application of the cayman tax to trusts
Previously, in its judgment of 11 March 2020 (A.R. no. 2018/4033/A unpublished)1, the Brussels court of first instance approved an agreement between the Belgium-resident founder of a Canadian trust and…
News
Draft bill to deny the deduction of interest and royalty payments to blacklisted countries as of 1 March 2021 has been passed.
The draft bill published on 30 March 2020 and introducing measures to deny the tax deduction of interest and royalty due to affiliated parties established in a blacklisted jurisdiction has…
News
FIDAL joins WTS Global in France
Tiberghien is pleased to announce a new development within the WTS Global network: since January 2021, the leading French law firm, FIDAL, has joined WTS Global. (read press release) This…
Publications
Real Estate Guide 2020
The WTS Global experts are happy to present to you the fifth edition of the Real Estate Investment Guide. As usual, the guide provides you with a comprehensive overview of…
Info COVID-19
What about import duties for the supply of medical devices?
In the light of decision 2020/491, the European Commission provides, next to the (temporarily) exemption of VAT for certain medical devices, an exemption of import duties that normally apply for…
News
Belgium anticipates DAC 7: New Belgian reporting obligations for digital platforms facilitating the provision of services
General Digital ‘collaboration’ platforms that connect suppliers of services to their customers are subject to new reporting obligations. These were introduced because many service providers (including Airbnb providers) allegedly do…
News
A Circular on interest limitation rules has been issued by the Luxembourg tax authorities
A new circular LIR 168bis/1 (the “Circular”), dated 8 January 2021, was published by the Luxembourg tax authorities on 8 January 2021. This Circular aims to clarify the interpretation and…
Publications
International Comparative Legal Guide - Private Client Laws and Regulations 2021
The International Comparative Legal Guide - Private Client covers common issues in private client laws – including pre-entry tax planning, connection factors, taxation issues on inward investment, succession planning, trusts…
Publications
Tiberghien comments on the OECD Blueprints on Pillar One and Pillar Two
Commenting on the OECD 'Blueprints' published on Monday 12 October, Koen Morbée, partner at Tiberghien Lawyers, and Andy Neuteleers, partner at Tiberghien Economics, urged the OECD Centre for Tax Policy…
News
HR tax & transfer pricing: an unexpected journey
Tiberghien and Tiberghien economics work together on HR tax and transfer pricing, which are two distinct fiscally- and economically-inspired disciplines that have more interaction than is often realised at first…
News
A new chapter in the UBO register saga: the Royal Decree of 23 September 2020
The implementation of the Belgian UBO register has turned into a real saga. The deadline for the first registration has been postponed up to three times (although the last time…
News
Year-end transfer pricing adjustments and their impact on customs & VAT
As the end of 2020 fast approaches, we notice that many multinational companies during the coming weeks/months often perform an annual assessment of transfer prices. The key question asked is:…
Publications
Taxation of Crypto Assets
Taxation of Crypto Assets begins with an overview of the technology and characteristics of crypto assets as well as the key tax concepts and types of taxes that could apply…
News
Luxembourg – France double tax treaty : clarifications on the 29-day threshold
A Circular L.G. – Conv. D.I. n°61 (“the Circular”) has been issued by the Luxembourg tax authorities on 21 October 2020 bringing some clarifications on the point 3 of the…
News
Luxembourg draft Budget Law 2021 announces several new tax measures
The Luxembourg Finance Minister Pierre Gramegna has filed on 14 October 2020 with the Chamber of Deputies the draft budget law for 2021. This draft bill introduces several new tax…
Publications
Private client law in Belgium: overview and Q&A
This extensive Q&A gives a high level overview of tax; tax residence; inheritance tax; buying property; wills and estate management; succession regimes; intestacy; trusts; charities; co-ownership; familial relationships; minority and…
News
T/A economics becomes TIBERGHIEN ECONOMICS
A NEW, YET FAMILIAR BRAND TO UNDERSCORE OUR HOLISTIC VIEW ON OUR CLIENT'S CHALLENGES AND ASPIRATIONS. We are excited to announce that, as per 1 October 2020, T/A economics will…
Events
Webinar – Post-COVID reality: How to manage the risk of double taxation
Publications
The Transfer Pricing Law Review - Chapter 2: Belgium
Although the arm’s-length principle, which forms the basis of the framework of transfer pricing rules, has had a long international history, it was only explicitly introduced into Belgian legislation in…
Publications
European law restrictions on the temporal effect of national juidicial decisions: the case of the Belgian Constitutional Court
The Belgian Constitutional Court is a court of law watching over the observance of the Constitution by the legislative authorities of Belgium. It has the power to annul, to declare…
News
Luxembourg introduces register for trusts and fiduciary arrangements
A new Luxembourg law (the “Trusts Register Law”), dated 10 July 2020, was published on 13 July 2020 and is in force since 17 July 2020.
News
Luxembourg to postpone DAC6 and DAC2 reporting deadlines
On 4 June 2020, the Luxembourg government announced that the negotiations on the European Commission proposal1 for a directive amending Council Directive 2011/16/EU dated 15 February 2011 that aims to postpone…
News
The ECJ takes positive decision on Italian FTT
In its decision of 30 April 2020, dealing with the Italian Financial Transaction Tax (FTT), the European Court of Justice (ECJ) has ruled that there is no violation of the…
News
Is the 18% of withholding tax on income paid to foreign artists and sportspersons no longer due?
On 13 May 2020, the Belgian political party, CD&V, submitted a draft bill to relax the 18% final withholding tax regime on income paid to foreign artists and sportspersons.
Info COVID-19
The value of the underlying shares has decreased (materially), resulting in the stock options being “under water”, meaning it is currently not interesting to exercise the stock options. What can we do?
A first possibility is to extend the exercise period of the stock options. Depending on the significance of the decrease of stock value, however, such an extension, potentially, needs to…