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New Belgium-Netherlands double tax treaty - Permanent establishment provisions amended in line with MLI

Thursday, 15 February 2024
The new double tax treaty between Belgium and the Netherlands will introduce significant changes  compared to the current Article 5 on permanent establishments. Due to the positions of Belgium and…
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(Shareholders of) corporate groups: beware of new cfc and cayman tax rules

Thursday, 08 February 2024
The Belgian legislator adopted new legislation on December 22, 2023, significantly modifying two sets of rules: (i) the CFC rules (“Controlled Foreign Corporation rules”) applicable to Belgian corporate taxpayers and…
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Withholding tax on Dividends, Interests and Royalties under the new Belgian - Dutch double tax treaty - Main changes

Tuesday, 16 January 2024
The withholding tax jurisdiction of the source state is limited to 15% for dividends, as before. Withholding tax may (no longer) be withheld when dividends are paid by subsidiaries to parent companies…
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European Court of Justice ruling: end of the application of VAT on director fees in Luxembourg

Thursday, 04 January 2024
On December 21, 2023, the European Court of Justice (“ECJ”) issued its long-awaited ruling in the case C288/22 “TP” on the VAT treatment of director fees. From a Luxembourg VAT…
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Belgium: The Belgian government also intends to, officially, make B2B e-invoicing mandatory

Monday, 08 January 2024
On 28 December 2023, the Belgian government submitted its proposal for a mandatory B2B invoicing scheme. Rumors for such an obligation were there since the end of 2022 and during…
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CAYMAN TAX 2.1 – sharpened teeth or mere dentures? A first update based on the draft bill as finally submitted to parliament.

Wednesday, 13 December 2023
PREFACE : This newsletter is only a first brief look at yet another very complex draft of cayman tax adjustment. Further analysis is recommended. This is an update of the…
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Luxembourg minimum net wealth tax provisions declared partly unconstitutional

Tuesday, 12 December 2023
Main takeaways On 10 November 2023, the Luxembourg Constitutional Court ruled that certain provisions of the Luxembourg minimum net wealth tax were contrary to constitutional principle of equality. Pending a…
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CAYMAN TAX 2.1 – sharpened teeth or mere dentures?

Friday, 03 November 2023
The draft bill approved at the Council of Ministers meeting on Friday, Oct. 27, 2023, proposes a whole number of changes to the cayman tax to ensure - in its…
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Two new partners join the ranks

Tuesday, 24 October 2023
Tiberghien is known for its long and rich tradition and is determined to continue its successful path forward. The firm is therefore constantly looking ahead, scanning opportunities for future investments…
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BEFIT, towards a common corporate tax framework in the EU ?

Friday, 13 October 2023
BEFIT stands for “Business in Europe: Framework for Income Taxation” and is the object of a draft EU directive proposed by the European Commission on 12 September 2023 (the “Draft…
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BREAKING NEWS: The new tax treaty between Luxembourg and the United Kingdom enters into force

Tuesday, 10 October 2023
On 4 October 2023, the law of 18 September 2023 was officially published in the Memorial (the Luxembourg official gazette), so that the new tax treaty between Luxembourg and the…
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Cayman tax remains applicable under new Dutch-Belgian double taxation treaty

Monday, 28 August 2023
The interaction of the Belgian cayman tax with the various double taxation treaties concluded by Belgium has been the subject of discussion in practice for several years. The question now…
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Accounting reform in Luxembourg - Draft law submitted to parliament

Thursday, 17 August 2023
Luxembourg government launched the first step of a reform of the Luxembourg accounting legal framework. The main objective is to consolidate into one single law the Luxembourg accounting rules currently…
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New double taxation treaty between Belgium and the Netherlands - implications for individual investors

Monday, 17 July 2023
The double taxation treaty between Belgium and the Netherlands, signed on 21 June 2023, will result in certain changes for private investors. The main concerns are the impact on the…
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Cross-border telework in Luxembourg: ongoing developments

Monday, 10 July 2023
Under the EU social security Framework Agreement, Luxembourg cross-border workers may telework more often from their state of residence without impacting their applicable social security legislation (provided telework represents less…
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CBAM regulation adopted on 10 May 2023

Monday, 10 July 2023
On 10 May 2023, the Council of the European Union and the European Parliament adopted the new regulation (EU) 2023/956 establishing a carbon border adjustment mechanism (CBAM). CBAM is designed…
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Breaking - The new double taxation treaty between the Netherlands and Belgium

Friday, 30 June 2023
On 21 June Belgium and the Netherlands signed a new double tax treaty on income taxes. Unlike under the current treaty, the scope of this treaty will be limited to…
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Brazil’ legislator enacts new transfer pricing law

Friday, 30 June 2023
On 15 June 2023, Brazil published a new law establishing a transfer pricing framework that is aligned with the OECD Transfer Pricing Guidelines (“OECD TPG”). Reforming Brazil’s transfer pricing (“TP”)…
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Luxembourg tax authorities issue guidance on reverse hybrid rules

Tuesday, 20 June 2023
On 9 June 2023, the Luxembourg direct tax authority (Administration des contributions directes, the “ACD”) released a 3-page circular – L.I.R n°168quater/1 (“Circular”) in relation to the so-called reverse hybrid…
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Cross-border telework: increase of social security threshold to 49%

Wednesday, 10 May 2023
The Administrative Commission for the Coordination of Social Security Systems of the European Union proposed a standard agreement aiming to increase the social security “threshold” for cross-border telework as from…
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