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International Tax Update: BAPA manual published by the OECD
Monday, 10 October 2022
The OECD Forum on Tax Administration has published on 28 September 2022 a manual on Bilateral Advance Pricing Arrangements, namely the Bilateral Advance Pricing Arrangement Manual (“BAPAM” or “Manual”). This BAPAM…
Will you file your first Belgian non-resident income tax return? Do not forget to register before 1 June 2022!
Tuesday, 10 May 2022
Individuals collecting income in Belgium and who qualify as Belgian tax non-residents, are in principle required to file a Belgian non-resident income tax return. Every single Belgian non-resident must fill…
115 account contributions and Luxembourg parent-subsidiary regime
Wednesday, 04 May 2022
Highlights On 31 March 2022, the Luxembourg Administrative Court of Appeal rendered a decision considering that 115 accounts contributions are not to be included in the acquisition price of the…
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…
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…
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.
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…
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…
The design of Covid-19 recovery contributions: Taxes or Social Security Contributions?
Tuesday, 28 December 2021
To cover the large financial spending caused by the Covid-19 pandemic, countries worldwide are forced to take substantial fiscal actions. This contribution takes a closer look at the extent to…
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…
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…