On 29 May 2017, the EU’s Council (in the Competitiveness Council configuration) formally adopted the Council Directive amending Directive (EU) 2016/1164 as regards hybrid mismatches with third countries (ATAD II) without further discussion. The amended Directive (ATAD II) has a broader scope than ATAD I as it also covers hybrid mismatches with third countries and
Update – Final (?) practice note on the increase of the tax free amount for dependents when fully/partially working abroad
Referring to our headlines of 15 July 2014 and 23 October 2015, the Belgian tax authorities recently published a new practice note on the increase of the tax free amount for dependents after the Court of Appeal in Antwerp rejected the last practice note in 2015. This practice note updates again the position of the Belgian
During its meeting on 23 May 2017, the ECOFIN Council reached an agreement on a proposal for a new system for resolving double taxation disputes within the EU. Based on the Convention on the elimination of double taxation in connection with the adjustment of profits of associated enterprises (the EU Arbitration Convention – 90/436/EEC), the
On 23 May 2017, the OECD released (under the impetus of the Final Report on BEPS Actions 8-10) a discussion draft which aims to giving guidance on the implementation of the approach to use ex post results as presumptive evidence about the ex ante pricing of transfers of hard-to-value intangibles (“HTVI”). The approach is described
Next to our own Salesforce world champion developer Joris Vanbelle, we have more colleagues that are Salesforce passionate at PwC, namely our up-and-coming Salesforce specialist Tim De Rycke.
As a recall, by request sent to the Constitutional Court, a Belgian taxpayer company has filed in January 2014 an action for annulment of the so-called Belgian ‘Fairness Tax’. This action comprises four different causes of action each of them including different headings or arguments: European law: freedom of establishment and Parent-Subsidiary Directive; Constitutional law: