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Latest news & developments

Circular 2019/C/14 – Addendum to the circular 2017/C/56 containing additional guidance on the transfer pricing documentation penalty regime

14 February 2019

On 8 February 2019, an addendum to the circular was issued containing additional guidance on the transfer pricing documentation penalty regime. General All companies and permanent establishments must prepare transfer pricing documentation unless they meet certain thresholds for exemption from filing documentation. Failing to file (in due time) the transfer pricing documentation (i.e. country-by-country report

Registration to the UBO register: extension of the deadline until 30 September

13 February 2019

We already informed you about the introduction in Belgium of a register regarding the Ultimate Beneficial Owners (UBO’s) of legal entities. Initially, the information on the UBO’s needed to be registered by 30 November 2018. However, the deadline had been extended till 31 March 2019 by the Federal Public Service Finance (FPSF) taken into account

Upcoming due date for electronic filing of BEPS 13 related documents: 28 February 2019

12 February 2019

Transfer pricing documentation has become an integral part of the compliance obligations of Belgian entities. The deadlines, criteria and formalities should therefore be followed up closely. Please find below a short summary of the obligations to be complied with by 28 February 2019. What? Belgian entities – if they meet certain criteria – have to

Belgian Net Asset Tax and Withholding Tax: opportunities to reclaim for Luxembourg SICAV

5 February 2019

In a decision dated 29 November 2018, the Court of Appeal of Brussels concluded that the Double Tax Treaty concluded between Belgium and Luxembourg (hereinafter the ‘DTT’) prevents the application of the Belgian Net Asset Tax (hereinafter the ‘NAT’) to a Luxembourg SICAV. As it confirms that a Luxembourg SICAV falls within the personal scope

2019 implementation of Belgian 30% EBITDA rule approved

1 February 2019

On 31 January 2019, the Chamber approved the advancement of the implementation date of the new interest limitation rule (30% EBITDA rule). The law will become effective after it is signed by the King and published in the Official Gazette. Concretely, this means that the Belgian 30% EBITDA rule will enter into force retroactively as from