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Luxembourg tax authorities update their Circular on interest limitation rules for members of a consolidated group
Thursday, 01 July 2021
On June 2nd, 2021, the Luxembourg tax authorities reissued their Circular n°168bis/1 dated January 8th, 2021 on the interest limitation rules governed by article 168bis of Luxembourg Income Tax Law…
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International Tax update: Evolving towards more OECD-compliancy: the times are changing in the Middle East
Tuesday, 29 June 2021
The Middle Eastern leg of the Tiberghien world tour showed some interesting developments in tax legislation of this region. These (expected) changes will undoubtedly have a big impact on MNE’s…
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Can tax related and IT services benefit from the VAT exemption for the management of special investment funds? The European Court of Justice says yes.
Tuesday, 29 June 2021
The Court of Justice of the European Union (ECJ) ruled in the joined cases K (C-58/20) and DBKAG (C-59/20) that the management of tax related responsibilities and the supply of…
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International Tax update: Mutual tax agreements mitigating the impact of Covid-19 telework for internationally active employees extended until the end of 2021
Friday, 25 June 2021
UPDATE 28/09/2021 Due to the Covid-19 pandemic, most employees have worked from home for a large number of days from March 2020 onwards. As the taxation of salaries and the applicable…
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Teleworking due to COVID 19: Luxembourg mutual tax agreements with Belgium, France and Germany still in force.
Tuesday, 22 June 2021
UPDATE Teleworking due to COVID 19: Luxembourg mutual agreements with Germany, Belgium and France will remain in force until the end of 2021 As covered more into detail here, a…
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Taxation of (ex-)partners and children
Tuesday, 22 June 2021
Some points of attention for spouses, legal cohabitants and separated parents You are separated or in the process of separating and are wondering how you will be taxed and who…
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International Tax update: EU Agreement with regard to Public country-by-country reporting for certain undertakings
Friday, 18 June 2021
On 1 June 2021 the EU Council negotiators and the negotiation team of the European Parliament reached a provisional political agreement on a proposed directive on the disclosure of income tax…
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International Tax update: Biden’s Green Book and the Old Continent
Tuesday, 15 June 2021
Last week the US Treasury Department released the long-awaited “Green Book”, explaining the tax proposals of the Biden Administration. The final version is shorter and less detailed than expected. Nevertheless,…
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International Tax update: The ECJ further defines the notion of a VAT fixed establishment
Tuesday, 08 June 2021
The Court of Justice of the European Union (ECJ) ruled in the Titanium case (C‑931/19) that own staff is required for a (sales) VAT fixed establishment (FE) to be present…
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Tax Treaty Making in Belgium. Well regulated?
Tuesday, 08 June 2021
The fact that Belgium has a wide network of double taxation conventions (‘tax treaties’) is positive for the Belgian economy and Belgian taxpayers. Each new tax treaty is welcomed. But…
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Tiberghien colleague Rik Smet receives honorable mention for prestigious award
Monday, 07 June 2021
In June last year our colleague Rik Smet successfully defended his doctoral thesis on tax treaty making in federations.
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International Tax update: Tiberghien World Tour PART I - AMERICAS
Friday, 04 June 2021
Last week, on 27 May 2021, we organized the first of four free interactive web events of our Tiberghien World Tour 2021. In these events, local experts of our WTS…
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International Tax update: European Commission’s view on business taxation in the 21th century
Friday, 28 May 2021
On May 18, 2021, the European Commission announced its vision on “Business Taxation for the 21st century”. It did so by means of a Communication to the European Parliament and…
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EU General Court judgements: Engie received illegal state aid, Amazon did not
Wednesday, 26 May 2021
On 12 May 2021, the EU General Court delivered two judgements relating to appeals made against the EU Commission’s decisions taken back in 2017 and 2018. In these decisions, the…
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International Tax update: Unexpected tax exposure for companies due to home office abroad?
Tuesday, 25 May 2021
As a result of the COVID-19 crisis, many cross-border workers are working from their home office, which is not necessarily located in the same country as their employer’ office. Also…
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New e-commerce VAT rules as from 1 July 2021: Watch out for double taxation on e-sales of imported goods with a value exceeding € 150
Wednesday, 19 May 2021
As from 1 July 2021, the e-commerce VAT package enters into force. As a result, online sales to private individuals will generally be subject to VAT in the EU Member…
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The CSSF has published a circular on teleworking for supervised entities in a non-pandemic situation
Monday, 17 May 2021
On 9 April 2021, the Luxembourg's financial sector supervisory authority (Commission de Surveillance du Secteur Financier - "CSSF") published CSSF Circular 21/769 on “Governance and security requirements for Supervised Entities…
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Tiberghien International Tax update: Wake-up call: European Parliament demands EU to take appropriate action in taxing the digital economy
Tuesday, 11 May 2021
On April 29th the European Parliament (“EP”) adopted its resolution “on digital taxation: OECD negotiations, tax residency of digital companies and a possible European Digital Tax”. The EP again reiterates…
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Tiberghien International Tax update: New withholding tax rules on UK sourced interest and royalty payments as from 1 June 2021
Friday, 07 May 2021
With the expiry of the Brexit transition period as of 1 January 2021, the United Kingdom is no longer bound by EU law, including the Interest and Royalties Directive (hereafter…
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An active UN adopts new UN model treaty provision regarding income from automated digital services
Tuesday, 04 May 2021
The UN has recently been very active in the area of taxation. On 20 April, the UN Committee of Experts on International Cooperation in Tax Matters agreed to adopting a…