Are the tax authorities ‘partying with you on stage’?
Monday, 13 March 2023
Many festivals have announced the first names for spring and summer 2023. We explain below the tax obligations for festival organisers with foreign artists on the bill.
Amendments to Hong Kong tax regime not sufficient? Update of the EU list on non-cooperative jurisdictions
Tuesday, 21 February 2023
Last week, the ECOFIN meeting of the Council of the EU took place, deciding on an update of the list of non-cooperative jurisdictions (the “black list”) and the list of…
Luxembourg double tax treaties update : UK, France and Germany
Monday, 13 February 2023
On 20 January 2023, the Luxembourg Council of Government took two different important decisions.
Christophe Dillen joins the partners of Tiberghien
Tuesday, 31 January 2023
Tiberghien continues to grow and evolve to provide its clients with forward-looking services of the highest standard. It is therefore with great pleasure that we announce the appointment as partner…
ATAD 3 and more: a brief update
Tuesday, 31 January 2023
In December last year, the European Parliament published a resolution on the proposal for a Directive laying down the rules to prevent misuse of shell entities for tax purposes (so-called…
An informal gift by way of bank transfer in cross-border context: points of interest
Thursday, 26 January 2023
The gift by way of bank transfer is a popular technique for making gifts to children or grandchildren. As this article will show, it involves more than simply transferring money…
Pillar Two/IFRS Newsflash: IASB consultation on IAS 12 amendements for Pillar Two
Thursday, 12 January 2023
On 9 January 2023, the International Accounting Standard Board (IASB) published Exposure Draft ED/2023/01 which contains important proposed amendments to IAS 12, the International Accounting Standard dealing with accounting for…
Belgian expat tax regime now extended to foreign non-profit organisations
Tuesday, 10 January 2023
On 1 January 2022, a new expat tax regime was introduced in Belgium that provides for a favourable income tax (and social security) treatment for employees, directors and researchers recruited…
Pillar Two - OECD’s Recently Released Safe Harbours and Penalty Relief Guidance : Solving key issues that MNEs face, or just a drop in the ocean?
Friday, 23 December 2022
On 20 December 2022, the OECD/G20 GloBE (Global Anti-Base Erosion) Inclusive Framework released, as part of a broader package, its Pillar Two Safe Harbour and Penalty Relief guidance document. Numerous…
Belgium - Luxembourg 34-day rule to be approved before year-end
Tuesday, 20 December 2022
On 31 August 2021, Belgium and Luxembourg signed a protocol increasing the 24-day tolerance to 34 days as from 2022.
Breaking: the EU’s Pillar Two Directive received required unanimous support
Tuesday, 13 December 2022
As mentioned in a previous newsflash, the EU Council published a slightly revised draft of the Pillar Two Directive on 25 November 2022. This was done in an attempt to…
Partial VAT deduction applying to the real use method: major changes from 1 January 2023
Tuesday, 13 December 2022
Existing cases: notification required by 30 June 2023 at the latest!
International Tax Update: The rise of the interest rate and the impact on valuations and transfer pricing
Wednesday, 07 December 2022
Behold, the era of free money is no more. This might be hard to digest for governments, companies and investors alike. After an extensive period of record-low interest rates and…
Newsflash: EU Council publishes updated draft Directive on global minimum taxation (Pillar Two) in light of next ECOFIN meeting of 6 December
Friday, 02 December 2022
Last year, the European Commission published, as a Christmas present, a proposal for a Directive on ensuring a global minimum level of taxation for multinational enterprise groups and large-scale domestic…
Luxembourg: interest free loan reclassified into equity – decision Administrative Tribunal
Thursday, 01 December 2022
In the judgement n°44902 dated 23 September 2022, the Tribunal Administrative (the “Tribunal”) requalified an interest free loan granted by a parent company to its subsidiary into equity on the…
European Court overturns public access to UBO register
Friday, 25 November 2022
In its judgment of 22 November 2022 (C37/20 & C/601/20), the European Court of Justice had to consider the compatibility of the UBO register and the fundamental rights to respect…
Credit of foreign inheritance tax on movable property: the Flemish legislator amends, or not quite?
Wednesday, 16 November 2022
The distinction between movable and immovable property for the credit of foreign inheritance tax is contrary to the constitutional principle of equality. This was decided by the Constitutional Court in…
UPDATE: Morocco postpones exchange of financial information, Belgian tax authorities eagerly investigate Turkish bank information
Thursday, 03 November 2022
Morocco has still not conducted a CRS exchange as of 30 September 2022. Morocco has announced a short delay due to technical and legislative reasons. It is expected that Morocco…
Luxembourg draft Budget Law 2023 announces several new tax measures
Wednesday, 02 November 2022
On 12 October 2022, the Luxembourg Minister of Finance Yuriko Backes has filed the draft budget law for 2023 (the “Draft Law”) with the Chamber of Deputies. In a difficult…
Breaking News - Constitutional Court’s decision on the annual tax on securities accounts (ATSA)
Thursday, 27 October 2022
This afternoon, the Belgian Constitutional Court has delivered its long-awaited judgment on the constitutionality of the annual tax on securities accounts introduced by the Act of February 17, 2021.