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News

Christophe Dillen joins the partners of Tiberghien

Tuesday, 31 January 2023

Tiberghien continues to grow and evolve to provide its clients with forward-looking services of the highest standard. It is therefore with great pleasure that we announce the appointment as partner…

News

ATAD 3 and more: a brief update

Tuesday, 31 January 2023

In December last year, the European Parliament published a resolution on the proposal for a Directive laying down the rules to prevent misuse of shell entities for tax purposes (so-called…

News

An informal gift by way of bank transfer in cross-border context: points of interest

Thursday, 26 January 2023

The gift by way of bank transfer is a popular technique for making gifts to children or grandchildren. As this article will show, it involves more than simply transferring money…

News

Pillar Two/IFRS Newsflash: IASB consultation on IAS 12 amendements for Pillar Two

Thursday, 12 January 2023

On 9 January 2023, the International Accounting Standard Board (IASB) published Exposure Draft ED/2023/01 which contains important proposed amendments to IAS 12, the International Accounting Standard dealing with accounting for…

News

Belgian expat tax regime now extended to foreign non-profit organisations

Tuesday, 10 January 2023

On 1 January 2022, a new expat tax regime was introduced in Belgium that provides for a favourable income tax (and social security) treatment for employees, directors and researchers recruited…

Publications

Fiscal Federalism in the EU. A Dynamic Process With Multiple Dimensions

Tuesday, 03 January 2023

In 2021 the European Association of Tax Law Professors held its annual conference on ‘History and Taxation’. One topic dealt with Fiscal Federalism. This concept refers to the study of…

News

Pillar Two - OECD’s Recently Released Safe Harbours and Penalty Relief Guidance : Solving key issues that MNEs face, or just a drop in the ocean?

Friday, 23 December 2022

On 20 December 2022, the OECD/G20 GloBE (Global Anti-Base Erosion) Inclusive Framework released, as part of a broader package[1], its Pillar Two Safe Harbour and Penalty Relief guidance document. Numerous…

News

Belgium - Luxembourg 34-day rule to be approved before year-end

Tuesday, 20 December 2022

On 31 August 2021, Belgium and Luxembourg signed a protocol increasing the 24-day tolerance to 34 days as from 2022.

News

Breaking: the EU’s Pillar Two Directive received required unanimous support

Tuesday, 13 December 2022

As mentioned in a previous newsflash, the EU Council published a slightly revised draft of the Pillar Two Directive on 25 November 2022. This was done in an attempt to…

News

Partial VAT deduction applying to the real use method: major changes from 1 January 2023

Tuesday, 13 December 2022

Existing cases: notification required by 30 June 2023 at the latest!

News

International Tax Update: The rise of the interest rate and the impact on valuations and transfer pricing

Wednesday, 07 December 2022

Behold, the era of free money is no more. This might be hard to digest for governments, companies and investors alike. After an extensive period of record-low interest rates and…

News

Newsflash: EU Council publishes updated draft Directive on global minimum taxation (Pillar Two) in light of next ECOFIN meeting of 6 December

Friday, 02 December 2022

Last year, the European Commission published, as a Christmas present, a proposal for a Directive on ensuring a global minimum level of taxation for multinational enterprise groups and large-scale domestic…

News

Luxembourg: interest free loan reclassified into equity – decision Administrative Tribunal

Thursday, 01 December 2022

In the judgement n°44902 dated 23 September 2022, the Tribunal Administrative (the “Tribunal”) requalified an interest free loan granted by a parent company to its subsidiary into equity on the…

News

European Court overturns public access to UBO register

Friday, 25 November 2022

In its judgment of 22 November 2022 (C37/20 & C/601/20), the European Court of Justice had to consider the compatibility of the UBO register and the fundamental rights to respect…

News

Credit of foreign inheritance tax on movable property: the Flemish legislator amends, or not quite?

Wednesday, 16 November 2022

The distinction between movable and immovable property for the credit of foreign inheritance tax is contrary to the constitutional principle of equality. This was decided by the Constitutional Court in…

News

UPDATE: Morocco postpones exchange of financial information, Belgian tax authorities eagerly investigate Turkish bank information

Thursday, 03 November 2022

Morocco has still not conducted a CRS exchange as of 30 September 2022. Morocco has announced a short delay due to technical and legislative reasons. It is expected that Morocco…

News

Luxembourg draft Budget Law 2023 announces several new tax measures

Wednesday, 02 November 2022

On 12 October 2022, the Luxembourg Minister of Finance Yuriko Backes has filed the draft budget law for 2023 (the “Draft Law”) with the Chamber of Deputies. In a difficult…

News

Breaking News - Constitutional Court’s decision on the annual tax on securities accounts (ATSA)

Thursday, 27 October 2022

This afternoon, the Belgian Constitutional Court has delivered its long-awaited judgment on the constitutionality of the annual tax on securities accounts introduced by the Act of February 17, 2021.

News

EU Court of Justice ruling on Belgian participation exemption regime in case of merger (DBI-aftrek/Régime RDT)

Wednesday, 26 October 2022

On October 20, 2022, the European Court of Justice (ECJ) delivered a ruling on the compatibility with the Parent-Subsidiary Directive of certain aspects of the Belgian participation exemption regime (“dividend…

News

Additional taxes for the Belgian financial sector

Friday, 21 October 2022

A little-publicized budgetary measure involving additional taxes for the financial sector could lead to a snowball of additional taxes on Belgian regulated investment companies.

News

International Tax Update: Arbitration procedures between the Netherlands and Luxembourg can take off

Thursday, 20 October 2022

The so-called multilateral instrument (‘MLI’) provides for a simultaneous modification of all double tax treaties which are considered by both signatories of the MLI as a ‘covered agreement’. The MLI…

Events
UA | UGent | KUL | ULB | KUL | UCL

Tiberghien at the job fairs in 2022!

News

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…

News

VAT treatment of Director fees in Luxembourg

Tuesday, 27 September 2022

On April 29, 2022, the Luxembourg District Court (“Tribunal d’Arrondissement”) submitted a reference for a preliminary ruling in the case TP vs Administration de l’Enregistrement, des Domaines et la TVA…

News

Tiberghien has four new counsels since 1 July 2022

Friday, 15 July 2022

Tiberghien has recently appointed Katrien Bollen, Elisabeth De Nolf, Ahmed El Jilali and Gert Vranckx as counsel, thus building further the firm’s growth and innovation. With these appointments we acknowledge…

News

Tiberghien has appointed two new partners

Thursday, 07 July 2022

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…

News

International Tax Update: ‘ATAD 3’ Update: (Probably) a little more time to prepare and avoid burdensome compliance obligations for in-scope entities

Wednesday, 29 June 2022

At the end of last year, the European Commission published a proposal for a directive to "tackle the misuse of shell entities for tax purposes" (see our previous newsflash on…

News

International Tax Update: Covid measures for social security applicable until year-end 2022

Tuesday, 21 June 2022

At the European level, it was decided to extend until 31 December 2022 the regime that the competent EU member state for social security does not change for teleworking frontier…

News

BREAKING NEWS: Luxembourg and the United Kingdom have concluded a new tax treaty

Monday, 20 June 2022

A new tax treaty, which replaces the treaty currently in force, was signed on 7 June 2022 in London between the Luxembourg and UK governments (the “Treaty”).

News

International Tax Update: End of covid measures for cross-border workers on 30 June 2022

Tuesday, 14 June 2022

:: UPDATE 21/06/2022 :: Due to the COVID-19 pandemic, a lot of employees who used to work abroad have been forced to work from home. In order to mitigate the impact,…

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