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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…

News

BREAKING: circular letter regarding expatriate tax regime has been published

Monday, 09 May 2022

Circular letter published Last week Friday, the Belgian tax administration published a circular letter regarding the reformed expat tax regime for incoming executives and researchers. This extensive letter aims to…

News

Key Figures in Belgian Estate and Income Tax 2022

Wednesday, 04 May 2022

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…

News

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…

News

Belgian reporting (tax) obligations for platform operators in anticipation of DAC 7 seem safe from an EU perspective

Wednesday, 04 May 2022

In our newsflash of 2 February 2021 (click here) we informed you that Belgium had anticipated the DAC 7 regulation and had already de facto transposed it into domestic law.…

News

International Tax Update: (When) Will transfer pricing in Brazil be more aligned with OECD standards?

Monday, 02 May 2022

On 12 April 2022, the OECD and the Brazilian tax authority (Brazil's Receita Federal (‘RFB’)) met in view of a proposed new transfer pricing system, which would be more aligned…

News

Legal cohabitants: Can your ex-partner claim maintenance?

Thursday, 14 April 2022

No maintenance expressly stipulated in the law for legal cohabitants In a judgment of 14 March 2017, the Antwerp Court of Appeal awarded a personal maintenance claim to an ex-partner…

News

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…

News

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…

News

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,…

News

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,…

News

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…

News

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…

News

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.

News

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…

News

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…

News

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…

News

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…

News

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…

News

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…

News

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…

Publications

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…

News

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…

News

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…

News

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…

News

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…

News

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.

News

International Tax Update: Public Country-by-Country Reporting takes last hurdle in legislation process

Wednesday, 17 November 2021

On 11 November 2021, the European Parliament approved the implementation of what is commonly referred to as the public country-by-country reporting (CbCR) Directive.1 This formal approval of the European Parliament came…

News

Breaking news : Belgium and France signed a new Double Tax Convention

Wednesday, 10 November 2021

On 9 November 2021, after long discussions and negotiations, France and Belgium signed a new Double Tax Convention (‘DTC’). Once the ratification process will be completed in both countries, this…

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