European Parliament’s draft report to the revised Parent Subsidiary Directive
On 28 January 2014, the European Parliament provided its draft report and draft amendments to the European Commission’s proposal for revision of the Parent-Subsidiary Directive. 1. Background On 25 November 2013, the European Commission has proposed certain amendments to the EU Parent-Subsidiary Directive in order to significantly reduce tax fraud/evasion and aggressive tax planning/base erosion and profit
New Global Standard for Automatic Exchange of Tax Information
In response to a mandate from G20 leaders aimed at reinforcing action against tax avoidance and evasion as well as introduce even greater trust and transparency into the international tax system, the OECD has unveiled today a new single global standard for the automatic exchange of information between tax authorities worldwide. Developed by the OECD
Latest VAT developments in Belgium for 2014
Further to the number of different VAT changes that have taken place in Belgium, we thought it important to provide you a short recap of all recent VAT developments that have come into force as from 2014 and which could have some impact on your business. If you have questions with regard to the changes
EU JTPF agrees on common criteria for acceptance of compensating adjustments
Download In January 2014, the EU Joint Transfer Pricing Forum (‘JTPF’) finalised its Report on Compensating Adjustments (‘the Report’). The document offers practical solutions to both EU tax administrations and taxpayers on how to deal with the issue of compensating adjustments. 1. Background The Report is the response of the JTPF on the level of
Current practice of different filing deadlines is unconstitutional
In a recent court case (Court of Appeal of Ghent, 26 January 2014), the Belgian courts have ruled that the current practice of the tax authorities of providing different filing deadlines, depending by whom (the taxpayer or representative) or the manner of filing (on paper or electronically) is unconstitutional, as this violates the general principles
Foreign Tax Credit (QFIE/FBB) System not Compliant to Belgian Constitution
Decision The Court examines two aspects of the legislation, (1) the possible refund of FTC in case of insufficient taxable profits and (2) the gross-up of the FTC to the corporate tax base (link to decision FR/ NL). 1. Excess FTC (article 285 and 292 ITC) Under domestic law, a foreign tax credit excess may
