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International Tax Update: Belgian tax authorities keep on referring to its own transfer pricing circular letter whereas the OECD Transfer Pricing Guidelines are the most relevant 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…
Publications

The design of Covid-19 recovery contributions: Taxes or Social Security Contributions?

To cover the large financial spending caused by the Covid-19 pandemic, countries worldwide are forced to take substantial fiscal actions. This contribution takes a closer look at the extent to…
News

International Tax Update: Dear tax administration: what you don’t publish can be used against you – but not against the taxpayer

How the MLI enters into effect between Belgium and the Netherlands, but is not opposable to the Belgian taxpayer (yet) In our previous international tax update we already indicated that…
News

International Tax Update: MLI to cover the Belgium – Netherlands tax treaty as of 1 January 2022

Somewhat unexpected and until today largely undetected, Belgium and the Netherlands have deposited notifications to the OECD Secretariat, with the intention of bringing their current double tax treaty under the…
News

VAT exemptions for logistics services and (sea)port activities: watch out for the VAT officer!

A recent VAT administrative circular letter, implementing EU VAT case law, has tightened the conditions for applying the VAT exemption for services in connection with the export of goods out…
News

International Tax Update: Important changes to the Belgian special taxation regime for foreign executives

The Belgian government agreed in the recent budgetary agreement on important changes for foreign executives falling under the special taxation regime.
News

International Tax Update: Digital Service Tax: Dead and done with?

On 8 October 2021, the already historical agreement about Pillars I and II was reached between 136 member jurisdictions of the OECD/G20 Inclusive Framework. A part of the overall agreement…
News

International Tax Update: Recent tax developments in Germany

German Real Estate Transfer Tax Rules for share deals As in Belgium, German Real Estate Transfer Tax (“RETT”) is triggered by the notarization of a direct real estate purchase. The…
News

Belgian Annual Tax on Securities Accounts challenged before Constitutional Court: annulment appeal is no suspension

With its Law of February 17, 2021, Belgium introduced a new annual tax on securities accounts (hereafter: “ATSA”), which has replaced the previously annulled tax on securities accounts that the…
News

International Tax update: Belgian Transfer Pricing Court Case

In a recently published decision dd. 8 June 2021 of the Court of Appeal of Ghent relating to transfer pricing (nr. 2016/AR/455), the Court decided in favor of the taxpayer.…
News

International Tax update: The Belgium - Luxembourg 24 day-rule becomes the 34 day-rule

The salary of a Belgian tax resident relating to days performed in Luxembourg is generally taxable in Luxembourg according to the Belgium-Luxembourg double tax treaty. The days worked outside of…
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