Events
Adults & Children in Postmodern Societies - International Family Law Conference
Events
International Tax Conference "Growth and Taxes"
News
Tiberghien opens new office in Ghent
09-05-2017 - Tiberghien, the specialist tax law firm with over 80 lawyers and the largest tax practice in Belgium, has opened a new office in Ghent. The new location is…
News
CbCR: Luxembourg implements Directive (EU) 2016/881, what are the lessons at this stage?
26-04-2017 - The process in Luxembourg has been particularly fast, with the entry into force of the new mechanism in domestic law less than 12 months after the adoption of…
News
New Belgian exit tax rules
26-04-2017 - Belgium introduces a deferred payment regime for companies required to pay exit taxes on outbound cross-border relocation of assets, migration or restructuring in line with article 5 of…
News
Belgian register of ultimate beneficiaries (“UBO-register”) is approaching
26-04-2017 - Under Articles 73 to 75 of the draft Bill on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing…
News
The CJEU’s Wereldhave judgment: Dutch investment funds with “Fiscal Investment Institution” status do not fall within the Parent-Subsidiary Directive’s scope
26-04-2017 Facts Two Dutch companies, Wereldhave International and Wereldhave, respectively own 35% and 44% of the Belgian company, Wereldhave Belgium. Both Dutch companies have the “Fiscal Investment Institution” (“fiscale beleggingsinstelling”)…
News
Taxation of pensions paid by Belgian debtors to non-residents: change of rules
26-04-2017 Pensions subject to Belgian non-resident income tax The Belgian Income Tax Code provides, as a basic rule, that occupational pensions paid to non-resident individuals are subject to tax in…
News
Belgium introduces exit tax rules as it implements ATAD
06-04-2017 - Belgium introduces a deferred payment regime for companies required to pay exit taxes on the cross-border relocation of assets, migration or restructuring in line with the EU Anti-Tax…
News
Tiberghien’s continued growth
03-04-17 In recent years, tax law firm Tiberghien has seen tremendous growth. Now, in addition to this organic growth, the tax lawyers of the law firm Dauginet, will be joining…
Publications
International double taxation in the European Union: comparative guidelines from Switzerland and the United States
27-03-2017 - The Court of Justice of the European Union (CJEU) ruled on several occasions that, while international double taxation may hinder the fundamental freedoms guaranteed by European Union (EU)…
News
New Belgian Innovation Profits Deduction (“IPD”)
2017-03-14 - After the abolition of the patent income deduction, the Belgian government announced on 2 December 2016 a new tax deduction for innovation profits. In line with the OECD’s recommendations…
News
VAT advance payments for quarterly VAT returns abolished from 1 April 2017
On 23 February 2017 a royal decree was published in the Belgian Official Gazette that abolishes the obligation for VAT taxable persons submitting quarterly VAT returns to make advance payments.…
News
T/A economics: Painting a new story...
... as the BeNeLux alternative for transfer pricing and valuation services, yet with a distinct approach. T/A economics is proud to announce its launch. T/A economics is a joint venture between…
Events
17th Annual Tax Planning Strategies - U.S. and Europe
Events
Symposium: The Belgian Reform of Succession Law from a Comparative Perspective
Publications
Income Taxation of Trusts in Belgium
Trusts do not exist under Belgian civil law. However, trusts governed by foreign law are generally analyzed by applying conflict of law rules. As a result, Belgium will generally recognize…
Events
Seminar STEP: 'Global and European Crossroads : Dutch and Belgian Cross-Border Estate Planning'
News
Luxembourg introduces new rules applicable to intra-group financing companies
1. Introduction The Luxembourg direct tax authorities issued on 27 December 2016 new guidelines by means of the issuance of Circular L.I.R. no. 56/1 – 56bis/1 (hereinafter the “Circular”) which…
News
Commission proposes new measures to modernize VAT for cross-border B2C e-commerce
On 1 December 2016, the European Commission has proposed various legislative changes to improve the current VAT rules on e-commerce1.
News
Advocate General ECJ: Fairness Tax contrary to art. 4 Parent-Subsidiary Directive
In a case pending before the European Court of Justice, the Court has been asked to determine whether the Belgian “Fairness Tax” is compatible with the freedom of establishment and…
News
The new Belgian REIF - Ready for 'take-off'
The Royal Decree containing the regulatory framework for the new Belgian Real Estate Investment Fund (“REIF”) has finally been published in the Belgian Official Gazette. Belgian and international real estate…
News
Does the finance structure of your real estate investments need to be reviewed?
Unfortunately, there is as yet no final agreement on a major reform of the Belgian corporate income tax system. However, increasing numbers of tax measures do not require an agreement…
Events
Morning lectures - Domestic anti-abuse rules and treaty override
Events
22nd Annual IBA International Wealth Transfer Practice Conference
News
Permanent establishments: recent developments
The notion of permanent establishment (‘PE’) and the attribution of profits to a PE continue to develop at an ever-increasing pace. Enterprises engaged in cross-border activities should keep a close…
News
Netherlands: proposals on cooperatives and dividend withholding tax
On the third Tuesday of September 2016, which is traditionally Budget Day in the Netherlands, the Deputy Minister of Finance sent a letter to the Dutch Parliament containing proposed changes…
News
Luxembourg: VAT on directors' fees
On 30 September 2016, the Luxembourg VAT Administration published the much awaited circular-letter on the VAT treatment of company directors (circular-letter 781).
News
New tax treaty between Belgium and Japan may stimulate cross-border investments
A new tax treaty between Belgium and Japan was signed on 12 October 2016. This treaty, once it becomes applicable, will significantly increase cross-border business opportunities for individuals and corporations…
News
Luxembourg: VAT on director fees
On 30 September 2016, the Luxembourg VAT Administration published the much awaited circular-letter on the VAT treatment of company directors (circular-letter 781). This circular-letter is the first official comment by…
Events
IBA Conference: The New Era of Taxation
Events
Special IFA Session: European Union State Aid Cases
News
Belgium applies VAT exemption for management of alternative collective investment funds
The Belgian VAT exemption for the management of investment funds has recently changed following the introduction of the new Belgian Real Estate Investment Trust (B-REIT). However, this change goes further…
Events
STEP Wyoming 2016: International Estate Planning Conference
Events
Special Half Day STEP New York Conference - Potpourri of Planning Strategies and Updates for North America and Europe
Events
70th Congress of the International Fiscal Association (IFA Congress 2016)
News
2017 Luxembourg Tax Reform | Draft law
On 26 July 2016 the Luxembourg Government submitted the draft law no. 7020 to the Luxembourg Parliament. The draft law includes a number of direct and indirect tax measures, most…
Publications
How does the CJEU's case law on cross-border loss relief apply to cross-border mergers and divisions?
The Merger Directive (Council Directive 2009/133/EC) is not a comprehensive piece of Union legislation covering all implications of cross-border reorganizations for the available tax losses of the companies involved in…
News
VAT exemption of intra-EU supplies : Belgian VAT authorities simplify the proof required.
On 1 July 2016, the Belgian VAT authorities published an important decision that should simplify the burden of proof requirements for the VAT exemption concerning intra-EU supplies.
News
Luxembourg Administrative Court confirms applicability of Advanced Tax Agreement
On 12 July 2016 the Luxembourg Administrative Court, the highest court in administrative matters in Luxembourg, confirmed the decision of the Luxembourg Administrative Tribunal of 16 December 2015, on the…
News
"It's Brexit!": the possible impact on VAT and customs duties
On 23 June 2016 voters in the UK decided to leave the European Union. This newsletter shortly describes the possible impact of the Brexit on VAT and customs duties.
News
The end of withholding tax on gross basis! : ECJ decision in Brisal Case
On July 13, 2016 the European Court of Justice rendered a milestone decision on withholding tax on interest payments within the EU (case C-18/15, Brisal – KBC Finance Ireland).
News
New EU Directive on VAT and vouchers
On 27 June 2016, the EU Council adopted a directive on transactions involving vouchers by harmonising national VAT rules in this area. The directive was adopted without discussion.
News
Redrafting VAT exemption for cost-sharing associations - action required
Belgian VAT law provides a specific exemption for cost-sharing associations, enabling groups of entities that have VAT exempt or out of scope activities to recharge costs without VAT. This VAT…
News
VAT on online gambling services postponed till August
In a previous article, we explained in detail the new VAT rules on e-gambling services. These services, which currently benefit from a specific VAT exemption for gambling services, will become…
News
Upcoming developments: a new Belgian real estate investment fund and the liberalisation of the existing SIR/GVV regime
The Belgian Federal government has recently announced new measures to make the Belgian real estate market more attractive to foreign investors. In particular, the creation of a new type of…