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International Tax Update: The Belgian tax slip obligation – no longer sanctioned as severely as before
Tuesday, 12 April 2022
Court of Justice decides In a recent judgment, the European Court of Justice addressed the obligation under Belgian law to draw up a summary tax slip for commissions paid and…
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Breaking: Ecofin one member state short of agreement on EU Directive on Pillar Two
Tuesday, 05 April 2022
In today’s Ecofin meeting an agreement was not reached regarding a new compromise text of an EU Directive on the introduction of Pillar Two in the European Union. Where at…
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International Tax Update: Stay on top of ever-changing local transfer pricing documentation requirements
Thursday, 17 March 2022
The Transfer Pricing documentation landscape is continuously evolving, whereby recently, there has been an increasing tendency of various countries updating and strengthening their transfer pricing documentation requirements. Considering these changes,…
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Interest limitation rules: Tax authorities adopt favorable position for the Private Equity sector
Friday, 11 March 2022
The Belgian Central Tax Authorities have recently taken an important decision on how the ATAD interest limitation rules must apply in the private equity (PE) sector. According to that decision,…
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CBN guidance on (de)mergers with entities having negative net asset values
Thursday, 10 March 2022
On February 15th, the Belgian accounting standards boards (Comissie voor Boekhoudkundige normen – hereafter “CBN”) published additional guidance with respect to mergers and demergers of companies having negative net asset…
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International Tax update: Fixed establishment through an affiliate company in Belgium? The Court of Appeal of Liège affirms.
Wednesday, 09 March 2022
Recently, the concept ‘fixed establishment’(‘FE’) for VAT purposes is the subject of many discussions and it seems that the saga will continue. In a judgement of 22 October 2021, the…
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Non-compete payment upon the ending of an international career... Taxation in the residence state?
Thursday, 24 February 2022
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International Tax Update: Expense allowances granted under the new expat tax regime are exempted from social security contributions
Friday, 11 February 2022
A new special tax regime for incoming executives and researchers entered into force in Belgium on 1 January 2022.
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Proposal for new European directive: the end of entities with little substance?
Thursday, 10 February 2022
On December 22, 2021, the European Commission published a potentially far-reaching proposal for a new directive. The aim of this proposal is to "tackle the misuse of undertakings that do…
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New Belgian special expat tax regime – who’s in?
Wednesday, 09 February 2022
A new expat tax regime for incoming executives and researchers entered into force in Belgium on 1 January 2022. Considering the change in the special tax regime’s scope, conditions and…
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International tax update: UAE introduces corporate income tax
Tuesday, 01 February 2022
Yesterday, 31 January 2022, the UAE Ministry of Finance announced the introduction of a federal corporate income tax (‘CIT’). For financial years starting on or after 1 July 2023, UAE…
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The Belgian ELTIF: ready for launch in 2022?
Thursday, 27 January 2022
ELTIF introduced mid 2021 By the Belgian Act containing various provisions of 27 June 2021 (Belgian Official Gazette 9 July 2021), the regime of a European Long Term Investment Fund…
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International Tax Update: 'New' 2022 OECD Transfer Pricing Guidelines: Bundling of earlier guidance
Thursday, 20 January 2022
The OECD published today the successor of the July 2017 edition of the Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (“OECD TP Guidelines”). This 'January 2022' edition of…
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International Tax Update: Belgian transfer pricing country profile at OECD.org refers to the latest Belgian transfer pricing circular letter, whereas arguably the OECD Transfer Pricing Guidelines are more relevant as a source of reference
Friday, 14 January 2022
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…
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The ultimate guide to get you through a transfer pricing audit
Friday, 07 January 2022
Did you or your company recently have to deal with a transfer pricing audit? If not, there is a good chance you will be faced with one soon. The number…
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International Tax Update: Dear tax administration: what you don’t publish can be used against you – but not against the taxpayer
Friday, 24 December 2021
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…
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International Tax Update: Tax treaties extend withholding tax benefits beyond the scope of European Directives - the example of interest paid to French société par actions simplifiée 'SAS'
Monday, 13 December 2021
Withholding tax exemption under EU law In the event of an allocation or payment of interest from a Belgian company to a company incorporated under foreign law, a withholding tax…
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International Tax Update: MLI to cover the Belgium – Netherlands tax treaty as of 1 January 2022
Friday, 10 December 2021
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…
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VAT exemptions for logistics services and (sea)port activities: watch out for the VAT officer!
Wednesday, 24 November 2021
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…
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International Tax Update: Important changes to the Belgian special taxation regime for foreign executives
Wednesday, 24 November 2021
The Belgian government agreed in the recent budgetary agreement on important changes for foreign executives falling under the special taxation regime.
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