Latest news & developments
CJEU rules in Stellantis: transfer pricing adjustments are not automatically consideration for VAT-taxable services
On 13 May 2026, the Court of Justice of the European Union (“CJEU”) issued its judgment in Stellantis Portugal (C-603/24), another important case on the VAT treatment of transfer pricing adjustments. Stellantis Portugal purchased vehicles from European group manufacturers and resold them to independent Portuguese dealers. Where vehicles were affected by manufacturing defects, warranty issues
Conflicting Belgian case law on transfer of excess interest deduction capacity – EU court to decide
The application of the 30% EBITDA interest limitation continues to give rise to significant uncertainty in Belgian acquisition structures. This uncertainty has now been elevated to EU level, as the court of first instance of Walloon Brabant has decided to refer a prejudicial question to the Court of Justice of the European Union. Under the
European Commission delivers its simplification review – The rules are set, now prepare
On 4 May 2026, the EU Commission published its simplification review of the EU Deforestation Regulation, together with a draft Delegated Act on product scope and updated FAQs (Version 5). The review refines the product scope through a draft Delegated Act. Soluble coffee, certain palm oil derivatives and frozen cattle tongues are proposed for inclusion, while leather
Investment deduction certificate – application deadline to be postponed
Further to our previous updates on the thematic investment deduction (see our newsflash of 16 January 2025 and our newsflash on the Royal Decree of 28 July 2025), the Flemish region recently announced on its website that an additional extension to the deadline for submitting certificate applications will be granted. This is, however, still subject to formal enactment by Royal Decree. Taxpayers must obtain a certificate
Tax bites podcast – Transfer Pricing audits
New Tax Bites episode out now! Pieter sits down with transfer pricing experts Ann and Brecht, and legal expert Véronique, to explore the changing Belgian TP audit landscape. Discover what happened to the traditional February audit “wave”, how audits are evolving and which companies and topics are being targeted. Get practical tips on prevention, managing
Belgium extends the filing deadline of the QDMTT and IIR Top-up Tax returns to 30 September 2026
What happened? The Belgian tax authorities have announced an extension of the filing deadline for the Qualified Domestic Minimum Top-up Tax (“QDMTT”) return and the Income Inclusion Rule (“IIR”) Top-up Tax Return. For returns for which the statutory filing deadline falls before 30 September 2026, the deadline has been extended to 30 September 2026. The due date
Updated Belgian inpatriate tax regime — New circular letter greenlights retroactive adjustments to employment contracts
On 1 April 2026, the Belgian tax authorities (BTA) published Circular letter 2026/C/51, providing commentary on the amendments made by the Law of 18 December 2025 to the special tax regime for inpatriate taxpayers (BBIB) and for inpatriate researchers (BBIO). The changes apply to remuneration paid or granted as from 1 January 2025. Without providing an overly extensive explanation of the special
EU Commission publishes guidance on the Packaging and Packaging Waste Regulation (PPWR)
On 30 March 2026, the European Commission published a guidance document and an accompanying set of Frequently Asked Questions (FAQs) on the implementation of the Packaging and Packaging Waste Regulation (PPWR) (Regulation (EU) 2025/40). These documents aim to facilitate the uniform application of the new packaging rules across the EU and to simplify compliance for economic operators and Member States. Background The
