Law on cross-border corporate restructurings

A law introducing some fundamental changes in the Belgian Income Tax Code with a view to implement EU Directive 2005/19/EC on the tax treatment of cross-border corporate restructurings has recently been published in the Belgian Official Gazette, and applicable to transactions carried out as of the date of its publication (12 January 2009). This means that it is now possible for multi-national enterprises to restructure their business within the EU in a tax neutral way. The new law also improves the tax neutrality of domestic corporate restructurings. In addition, the company law requirements relating to cross-border mergers, as provided by Directive 2005/56/EC, have recently been included in the Belgian Company Code by the Law of May 8, 2008.