News
EU General Court judgements: Engie received illegal state aid, Amazon did not
On 12 May 2021, the EU General Court delivered two judgements relating to appeals made against the EU Commission’s decisions taken back in 2017 and 2018. In these decisions, the…
News
International Tax update: Unexpected tax exposure for companies due to home office abroad?
As a result of the COVID-19 crisis, many cross-border workers are working from their home office, which is not necessarily located in the same country as their employer’ office. Also…
News
New e-commerce VAT rules as from 1 July 2021: Watch out for double taxation on e-sales of imported goods with a value exceeding € 150
As from 1 July 2021, the e-commerce VAT package enters into force. As a result, online sales to private individuals will generally be subject to VAT in the EU Member…
News
The CSSF has published a circular on teleworking for supervised entities in a non-pandemic situation
On 9 April 2021, the Luxembourg's financial sector supervisory authority (Commission de Surveillance du Secteur Financier - "CSSF") published CSSF Circular 21/769 on “Governance and security requirements for Supervised Entities…
Events
Tiberghien World Tour: Asia-Pacific (web event)
Events
Tiberghien World Tour: Middle East & Africa (web event)
Events
Tiberghien World Tour: Americas (web event)
News
Tiberghien International Tax update: Wake-up call: European Parliament demands EU to take appropriate action in taxing the digital economy
On April 29th the European Parliament (“EP”) adopted its resolution “on digital taxation: OECD negotiations, tax residency of digital companies and a possible European Digital Tax”. The EP again reiterates…
News
Tiberghien International Tax update: New withholding tax rules on UK sourced interest and royalty payments as from 1 June 2021
With the expiry of the Brexit transition period as of 1 January 2021, the United Kingdom is no longer bound by EU law, including the Interest and Royalties Directive (hereafter…
News
An active UN adopts new UN model treaty provision regarding income from automated digital services
The UN has recently been very active in the area of taxation. On 20 April, the UN Committee of Experts on International Cooperation in Tax Matters agreed to adopting a…
News
Key Figures in Belgian Estate and Income Tax 2021
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…
News
Are tax authorities allowed to exclude persons from forming a VAT group? The European Court of Justice enlightens us again
Decision of the Court On April 15, 2021, the European Court of Justice issued its ruling in the case C-868/19 “M-GmbH” on the scope of the VAT group provisions. In…
News
Luxembourg clarifies financial assistance rules for private limited liability companies (SARL)
Draft bill N°7791, submitted to the Luxembourg Parliament (Chambre des Députés) on 16 March 2020, proposes to amend article 1500-7 of the law of 10 August 1915 on commercial companies,…
News
The Belgium / Luxembourg 24 day-rule: update
Belgian tax resident working in Luxembourg If a Belgian tax resident works in Luxembourg, the question arises where the Luxembourgish salary is taxable. This may be relevant considering the lower…
News
The OECD’s Discussion draft on changing the Commentary on Article 9 (and others)
Article 9 of the OECD Model Tax Convention deals with the (distribution of) taxation (rights in respect) of transactions between associated enterprises. The OECD now proposes changes to the Commentary…
News
Can MLI arbitration finally kick off?
First competent authority agreement regarding MLI arbitration published The Multilateral convention to implement tax treaty related measures to prevent base erosion and profit shifting (‘MLI’) provides the possibility for a…
News
E-commerce: Avoid VAT compliance obligations abroad and register now for the One Stop Shop (OSS)
From 1 July 2021, companies selling goods via web shops will have to deal with foreign VAT and the related obligations much sooner when selling goods to private individuals in…
News
New EU tax transparency rules for digital platform operators officially adopted and published: DAC 7 enters into force in 2023
The European Union Member States agreed to a new measure to tackle the challenges they face when taxing the digital economy. One of the crucial elements for this to succeed…
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…
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Tiberghien Tax Law Manual
