Brazil enacts new rules impacting dividend withholding, interest deductions, goodwill amortization and CFCs
The Brazilian government on May 14, 2014 enacted Law No. 12.973/2014, converting into law Provisional Measure 627/2013 (PM 627). The key provisions of the enacted law are the revocation of the Transitional Tax Regime (RTT) and new rules regarding the treatment of dividends, interest on net equity (INE), amortization of goodwill, and controlled foreign corporations
6th State reform: Taxation of individuals – Changes published
On the 28th of May 2014 the law reforming the Belgian Income Tax Code in light of the 6th state reform has been published in the Official Gazette. Due to this state reform Regions (Flanders, Brussels and Wallonia) will obtain increased fiscal autonomy. A portion of the personal income tax will be attributed to the
Luxembourg – Adoption of law revising corporate exit tax rules
On 13 May 2014, the Luxembourg Parliament approved the law (bill n. 6556) amending some of Luxembourg tax provisions that were considered not to be compliant with EU law. The changes are most notably in the area of exit taxation for corporate entities. Key changes: Deferral of the tax liabilities arising upon migration; and “Roll-over”
Parliamentary question regarding the application of Belgian thin cap rules for cash pooling activities
The Minister of Finance answered a Parliamentary question on how the Belgian thin cap rules should be applied in practice to cash pooling activities. The Minister was asked a.o. how a daily assessment of the 5:1 debt-equity ratio links in with the netting of interest paid and received for cash pooling companies (for more information
Challenges multinationals may face in completing the OECD’s country-by-country reporting template
On 30 January 2014, the Organisation for Economic Cooperation and Development (OECD) released a discussion draft on transfer pricing documentation and country-by-country reporting (CBCR) which included a template for reporting of income, taxes, and economic activity (CBCR template). The purpose of the CBCR template is to provide tax authorities with the information necessary to conduct
Personal income taxes – Calculation of the tax surcharge due to late tax filing
Based on the Belgian Income Tax Code 1992, when a taxpayer does not file a tax return or files an incomplete or incorrect tax return, a tax surcharge is applied ‘on the tax in relation to the non-declared income’. The tax surcharge can also be applied in case of late filing. The amount of the
Good faith transitional relief under FATCA provided by US Treasury and IRS
On May 2, 2014, the US Treasury Department (Treasury) and Internal Revenue Service (IRS) announced in Notice 2014-33 (the Notice) that calendar years 2014 and 2015 will be regarded as a transition period for IRS enforcement and administration purposes with respect to the implementation of the Foreign Account Tax Compliance Act (FATCA or Chapter 4).
EU FTT
EU FTT: UK’s challenge blocked for now but UK Treasury indicates they will not let it be. In april 2013, the UK launched a legal challenge against the introduction of an EU Financial Transaction Tax (‘EU FTT’) under the Enhanced Cooperation Procedure (‘ECP’). Two days before, the Court of Justice of the European Union (‘CJEU’) released