News, 20 August, 2024
On 31 July 2024, the Luxembourg Administrative Court applied the specific anti-abuse rule of the Parent-Subsidiary Directive as transposed into the Luxembourg income tax law (PSD SAAR) for the first time in a case involving the in-kind repayment of a profit participating facility (PPF) by a Belgian subsidiary to its…
News, 7 June, 2024
The Belgian Pillar 2 transposition law was recently amended, in part to incorporate the most recent additional OECD Commentary. This law also provides that “Pillar 2 groups” will (have to) have a separate CBE registration (‘Crossroads Bank for Enterprises’). This should simplify relations with the tax administration by providing only…
News, 11 April, 2024
The Belgian tax authorities recently initiated the 2024 transfer pricing audit wave, starting with a questionnaire and a pre-audit meeting.