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International Tax Update: Covid measures for social security applicable until year-end 2022

At the European level, it was decided to extend until 31 December 2022 the regime that the competent EU member state for social security does not change for teleworking frontier…

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BREAKING NEWS: Luxembourg and the United Kingdom have concluded a new tax treaty

A new tax treaty, which replaces the treaty currently in force, was signed on 7 June 2022 in London between the Luxembourg and UK governments (the “Treaty”).

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International Tax Update: End of covid measures for cross-border workers on 30 June 2022

:: UPDATE 21/06/2022 :: Due to the COVID-19 pandemic, a lot of employees who used to work abroad have been forced to work from home. In order to mitigate the impact,…

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International Tax Update: New social security agreement between Belgium and Morocco

Belgium and Morocco negotiated a new bilateral agreement on social security in 2014. After going through the ratification procedures in both countries, the agreement will enter into force on the…

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International Tax Update : Tax treaties with China and Hong Kong to be covered by the MLI

On 25 May 2022, China has deposited its instrument of ratification for the MLI with the OECD. This means that this treaty will enter into force as of 1 September…

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International Tax Update: A proposal for a Directive on debt-equity bias reduction allowance (DEBRA)

On 11 May 2022, the European Commission published a proposal for a Directive providing for a debt-equity bias reduction allowance (‘DEBRA’). This directive is part of the Commission’s proposed measures…

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Luxembourg treaty exemption for the Annual Tax on Securities Accounts at risk?

The Annual Tax on Securities Accounts (hereafter: "ATSA") is applicable (among other things) to securities accounts held in Belgium, even if they are held by non-Belgian residents/account holder. Both the…

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Will you file your first Belgian non-resident income tax return? Do not forget to register before 1 June 2022!

Individuals collecting income in Belgium and who qualify as Belgian tax non-residents, are in principle required to file a Belgian non-resident income tax return. Every single Belgian non-resident must fill…

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BREAKING: circular letter regarding expatriate tax regime has been published

Circular letter published Last week Friday, the Belgian tax administration published a circular letter regarding the reformed expat tax regime for incoming executives and researchers. This extensive letter aims to…

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Key Figures in Belgian Estate and Income Tax 2022

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…

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115 account contributions and Luxembourg parent-subsidiary regime

Highlights On 31 March 2022, the Luxembourg Administrative Court of Appeal rendered a decision considering that 115 accounts contributions are not to be included in the acquisition price of the…

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Belgian reporting (tax) obligations for platform operators in anticipation of DAC 7 seem safe from an EU perspective

In our newsflash of 2 February 2021 (click here) we informed you that Belgium had anticipated the DAC 7 regulation and had already de facto transposed it into domestic law.…

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International Tax Update: (When) Will transfer pricing in Brazil be more aligned with OECD standards?

On 12 April 2022, the OECD and the Brazilian tax authority (Brazil's Receita Federal (‘RFB’)) met in view of a proposed new transfer pricing system, which would be more aligned…

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Legal cohabitants: Can your ex-partner claim maintenance?

No maintenance expressly stipulated in the law for legal cohabitants In a judgment of 14 March 2017, the Antwerp Court of Appeal awarded a personal maintenance claim to an ex-partner…

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International Tax Update: The Belgian tax slip obligation – no longer sanctioned as severely as before

Court of Justice decides In a recent judgment, the European Court of Justice addressed the obligation under Belgian law to draw up a summary tax slip for commissions paid and…

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Breaking: Ecofin one member state short of agreement on EU Directive on Pillar Two

In today’s Ecofin meeting an agreement was not reached regarding a new compromise text of an EU Directive on the introduction of Pillar Two in the European Union. Where at…

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International Tax Update: Stay on top of ever-changing local transfer pricing documentation requirements

The Transfer Pricing documentation landscape is continuously evolving, whereby recently, there has been an increasing tendency of various countries updating and strengthening their transfer pricing documentation requirements. Considering these changes,…

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Interest limitation rules: Tax authorities adopt favorable position for the Private Equity sector

The Belgian Central Tax Authorities have recently taken an important decision on how the ATAD interest limitation rules must apply in the private equity (PE) sector. According to that decision,…

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CBN guidance on (de)mergers with entities having negative net asset values

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…

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International Tax update: Fixed establishment through an affiliate company in Belgium? The Court of Appeal of Liège affirms.

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…

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Non-compete payment upon the ending of an international career... Taxation in the residence state?

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International Tax Update: Expense allowances granted under the new expat tax regime are exempted from social security contributions

A new special tax regime for incoming executives and researchers entered into force in Belgium on 1 January 2022.

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Proposal for new European directive: the end of entities with little substance?

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…

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New Belgian special expat tax regime – who’s in?

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…

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International tax update: UAE introduces corporate income tax

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…

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The Belgian ELTIF: ready for launch in 2022?

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…

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

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…

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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

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…

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The ultimate guide to get you through a transfer pricing audit

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…