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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…
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Key Figures in Belgian Estate and Income Tax 2021
Wednesday, 28 April 2021
The continuing changes in Belgian Estate and Income tax, together with the growing discrepancies between the three Belgian regions, are generating a tangle of regulations that are sometimes hard to…
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Are tax authorities allowed to exclude persons from forming a VAT group? The European Court of Justice enlightens us again
Friday, 23 April 2021
Decision of the Court On April 15, 2021, the European Court of Justice issued its ruling in the case C-868/19 “M-GmbH” on the scope of the VAT group provisions. In…
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Luxembourg clarifies financial assistance rules for private limited liability companies (SARL)
Wednesday, 21 April 2021
Draft bill N°7791, submitted to the Luxembourg Parliament (Chambre des Députés) on 16 March 2020, proposes to amend article 1500-7 of the law of 10 August 1915 on commercial companies,…
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The Belgium / Luxembourg 24 day-rule: update
Tuesday, 20 April 2021
Belgian tax resident working in Luxembourg If a Belgian tax resident works in Luxembourg, the question arises where the Luxembourgish salary is taxable. This may be relevant considering the lower…
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The OECD’s Discussion draft on changing the Commentary on Article 9 (and others)
Friday, 16 April 2021
Article 9 of the OECD Model Tax Convention deals with the (distribution of) taxation (rights in respect) of transactions between associated enterprises. The OECD now proposes changes to the Commentary…
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Can MLI arbitration finally kick off?
Tuesday, 13 April 2021
First competent authority agreement regarding MLI arbitration published The Multilateral convention to implement tax treaty related measures to prevent base erosion and profit shifting (‘MLI’) provides the possibility for a…
