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Key Figures in Belgian Estate and Income Tax 2024
Monday, 20 May 2024
The Belgian Estate and Income tax is characterised by continuous changes and the differences between the three regions are becoming more and more pronounced. We would like to help you…
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2024 transfer pricing audit wave
Thursday, 11 April 2024
The Belgian tax authorities recently initiated the 2024 transfer pricing audit wave, starting with a questionnaire and a pre-audit meeting.
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Tiberghien Lawyers ranked 'Tier 1' in LEGAL500 for Tax
Thursday, 04 April 2024
We are extremely proud to announce that Tiberghien Lawyers have been awarded a 'Tier 1' ranking for tax by Legal500 - 2024 edition, that makes 9 times in a row…
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The UK Spring Budget 2024: Replacement of the “non-dom” tax status (RND) by a new four-year foreign income and gains (FIG) regime as of 6 April 2025 – impact on Income Tax, Inheritance Tax (IHT) and trusts
Friday, 15 March 2024
The UK recently announced important tax reforms in its Spring Budget 2024. The proposed changes are relevant for individuals who are resident but not domiciled in the UK (so-called “non-doms”…
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Rules on allocation of taxing rights on immigration and emigration of individuals under the new Belgian - Dutch Double Tax Treaty: main changes
Monday, 04 March 2024
In an earlier article in this series, we already discussed the planned changes in terms of moveable income. Whilst the changes may seem relatively limited at first glance, Dutch residents…
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Navigating the Nuances: The Administrative Court's Interpretation of Loan vs. Equity Characteristics
Thursday, 29 February 2024
On 23 November 2023, in case number 48125C, the Luxembourg Administrative Court overruled a decision rendered by the Administrative Tribunal on 23 September 2022.
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Tiberghien moves to Tweetorenwijk in Hasselt
Thursday, 22 February 2024
We are proud to announce our new location in the heart of Hasselt. This move represents a significant strengthening of our presence in the region.
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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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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…