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International Tax Update: 'New' 2022 OECD Transfer Pricing Guidelines: Bundling of earlier guidance

Thursday, 20 January 2022

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…

News

International Tax Update: Belgian transfer pricing country profile at OECD.org refers to the latest Belgian transfer pricing circular letter, whereas arguably the OECD Transfer Pricing Guidelines are more relevant as a source of reference

Friday, 14 January 2022

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…

News

The ultimate guide to get you through a transfer pricing audit

Friday, 07 January 2022

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…

Publications

The design of Covid-19 recovery contributions: Taxes or Social Security Contributions?

Tuesday, 28 December 2021

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…

News

International Tax Update: Dear tax administration: what you don’t publish can be used against you – but not against the taxpayer

Friday, 24 December 2021

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…

News

International Tax Update: Tax treaties extend withholding tax benefits beyond the scope of European Directives - the example of interest paid to French société par actions simplifiée 'SAS'

Monday, 13 December 2021

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…

News

International Tax Update: MLI to cover the Belgium – Netherlands tax treaty as of 1 January 2022

Friday, 10 December 2021

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…

News

VAT exemptions for logistics services and (sea)port activities: watch out for the VAT officer!

Wednesday, 24 November 2021

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…

News

International Tax Update: Important changes to the Belgian special taxation regime for foreign executives

Wednesday, 24 November 2021

The Belgian government agreed in the recent budgetary agreement on important changes for foreign executives falling under the special taxation regime.

News

International Tax Update: Public Country-by-Country Reporting takes last hurdle in legislation process

Wednesday, 17 November 2021

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…

News

Breaking news : Belgium and France signed a new Double Tax Convention

Wednesday, 10 November 2021

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…

News

International Tax Update: Digital Service Tax: Dead and done with?

Wednesday, 27 October 2021

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…

News

International Tax Update: Recent tax developments in Germany

Tuesday, 05 October 2021

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…

News

Belgian Annual Tax on Securities Accounts challenged before Constitutional Court: annulment appeal is no suspension

Thursday, 23 September 2021

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…

News

International Tax update: Excess profit rulings: Victory for the European Commission?

Friday, 17 September 2021

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…

News

International Tax update: Belgian Transfer Pricing Court Case

Thursday, 16 September 2021

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.…

News

International Tax update: The Belgium - Luxembourg 24 day-rule becomes the 34 day-rule

Tuesday, 07 September 2021

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…

News

Luxembourg Newsflash: New administrative circular sets guidelines for the imposition of tax fines

Monday, 09 August 2021

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…

News

VAT registration with a fiscal representative in Belgium: new guarantee rules will create more burdens for foreign taxpayers

Wednesday, 28 July 2021

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.…

News

VAT and e-commerce: Belgium implements new rules on importer of record

Friday, 09 July 2021

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…

News

Asia is stepping up its tax game: faceless tax audits, major tax reforms and much more

Friday, 02 July 2021

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…

News

Luxembourg tax authorities update their Circular on interest limitation rules for members of a consolidated group

Thursday, 01 July 2021

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…

News

International Tax update: Evolving towards more OECD-compliancy: the times are changing in the Middle East

Tuesday, 29 June 2021

The Middle Eastern leg of the Tiberghien world tour showed some interesting developments in tax legislation of this region. These (expected) changes will undoubtedly have a big impact on MNE’s…

News

Can tax related and IT services benefit from the VAT exemption for the management of special investment funds? The European Court of Justice says yes.

Tuesday, 29 June 2021

The Court of Justice of the European Union (ECJ) ruled in the joined cases K (C-58/20) and DBKAG (C-59/20) that the management of tax related responsibilities and the supply of…

News

International Tax update: Mutual tax agreements mitigating the impact of Covid-19 telework for internationally active employees extended until the end of 2021

Friday, 25 June 2021

UPDATE 28/09/2021 Due to the Covid-19 pandemic, most employees have worked from home for a large number of days from March 2020 onwards. As the taxation of salaries and the applicable…

News

Teleworking due to COVID 19: Luxembourg mutual tax agreements with Belgium, France and Germany still in force.

Tuesday, 22 June 2021

UPDATE Teleworking due to COVID 19: Luxembourg mutual agreements with Germany, Belgium and France will remain in force until the end of 2021 As covered more into detail here, a…

News

Taxation of (ex-)partners and children

Tuesday, 22 June 2021

Some points of attention for spouses, legal cohabitants and separated parents You are separated or in the process of separating and are wondering how you will be taxed and who…

News

International Tax update: EU Agreement with regard to Public country-by-country reporting for certain undertakings

Friday, 18 June 2021

On 1 June 2021 the EU Council negotiators and the negotiation team of the European Parliament reached a provisional political agreement on a proposed directive on the disclosure of income tax…

News

International Tax update: Biden’s Green Book and the Old Continent

Tuesday, 15 June 2021

Last week the US Treasury Department released the long-awaited “Green Book”, explaining the tax proposals of the Biden Administration. The final version is shorter and less detailed than expected. Nevertheless,…

News

International Tax update: The ECJ further defines the notion of a VAT fixed establishment

Tuesday, 08 June 2021

The Court of Justice of the European Union (ECJ) ruled in the Titanium case (C‑931/19) that own staff is required for a (sales) VAT fixed establishment (FE) to be present…

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