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Latest news & developments

Update – Fast Track Ruling – Homeworking (Expense Allowance)

2 June 2020

We refer to our newsflash of 19 March on the implementation of the Fast Track Ruling (Fast Track Ruling – Homeworking, Expense Allowance). On 29 May, the Rulings Office (Dienst Voorafgaande Beslissingen in Fiscale Zaken/Services des Décisions anticipées en Matières Fiscales) published on its website a new COVID-19 application model document that has been slightly adjusted

The impact of COVID-19 on routine profits

29 May 2020

Evidencing downward adjustments for limited risk entities commands more than a quick browse through high-level macroeconomic trends. As many companies consider to adjust their transfer pricing (TP) policies as a result of the current economic situation, we’ve performed a robust macroeconomic analysis linked to some 180,000 company data points. The approach is rooted in work

Update COVID-19 and cross-border employment: agreement between Belgium and Luxembourg on home working

25 May 2020

As highlighted in our previous newsflashes, Belgium has recently concluded mutual agreements with the Netherlands, Germany and France regarding a “force majeure” approach for cross-border workers. An agreement with Luxembourg was still missing. However, the Belgian government has now published the Belgian-Luxembourg agreement recognising the ‘force majeure’ character of the COVID-19 health crisis and introducing

COVID-19: impact on the expatriate tax regime in Belgium

24 May 2020

Even though national containment measures, to flatten the curve and ultimately stop the further spreading of the coronavirus, are gradually being phased out by many countries and we can even start to see a silver lining, the COVID-19 pandemic has a major impact on how people and organisations are functioning today and how they will

COVID-19 #16 Change of control – impact on tax attributes

20 May 2020

A staggering US$2,500bn. That’s the estimated ‘dry powder’ currently held by private equity firms at a global level. Although a lot of that money is likely to be invested in businesses that are coping (reasonably) well with the ongoing crisis, troubled sectors may nonetheless see a greater deal of activity as they may present opportunities

Update COVID-19 and cross-border employment: agreement between Belgium and France on home working

20 May 2020

The exceptional COVID-19 situation resulted in various government introduced measures which are themselves also exceptional and which are aiming to combat the spread of the coronavirus. Measures such as international travel restrictions, quarantine and lockdown (in whatever form or degree), also impact international business travel and prevent cross-border workers from carrying out their professional activities

COVID-19: New supportive Belgian tax measures

20 May 2020

On 16 May 2020, after the first wave of supportive measures to mitigate the consequences of the COVID-19 crisis, the Council of Ministers adopted a draft law including new tax recovery measures. These provisions have as main aim to avoid a series of bankruptcies and to help companies to rebuild their liquidity and solvency positions.

Administrative circular on spin-off transactions

19 May 2020

On April 20th, 2020, the Belgian Tax Administration issued the  circular 2020/C/55 further detailing the tax treatment of spin-off transactions according to article 264, first paragraph, 4° of the BITC 92. Context As a reminder, the so-called spin-off transactions are not demerger transactions nor transactions assimilated to a demerger, as defined by article 2, §1,