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…
Following an intense debate, the legislator introduced a new tax scheme applicable to copyright income. Main raison for this initiative is the assumed abuse of the until then beneficial tax…
Griet Vanden Abeele, Alain Van Geel and Emilie Van Goidesenhoven contributed to the International Comparative Legal Guide (ICLG) - Private Client 2023. This publication covers common issues in private client…
Many festivals have announced the first names for spring and summer 2023. We explain below the tax obligations for festival organisers with foreign artists on the bill.
Last week, the ECOFIN meeting of the Council of the EU took place, deciding on an update of the list of non-cooperative jurisdictions (the “black list”) and the list of…
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…
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…
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…
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…
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…
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…
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…
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…
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…
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…
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…
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…
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…
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…
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…
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.
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…
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.
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…
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…
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…