COVID-19 #6 Cash repatriation – capital reduction
Next to dividend distributions and (early) repayment of intercompany loans, a group may also consider a capital reduction to repatriate cash to the upper tier structure. Whereas a reduction of fiscally paid-up capital is in principle tax neutral between corporates, it may still have some (unexpected) tax consequences. Item #6: A capital reduction is not
NEDC vs NEDC 2.0 vs WLTP: new (updated) FAQs regarding the percentage of deduction of professional car expenses and calculation of the BIK for employees
A new FAQ has been published by the Belgian Tax Authorities that explains which CO2 emission value has to be used for the calculation of the deductible rate of company car expenses (FAQ, 25 March 2020). Indeed, using the WLTP or even the NEDC 2.0 emission value will lead to an increase of the car
COVID-19: a multi country overview of supportive measures – update
COVID-19 presents significant challenges to people and organisations around the globe and the disruption continues to evolve. We know that your business is facing several potentially significant tax challenges to which you need to respond rapidly. To help you cut through the complexity, PwC’s team of specialists collaborated to create a resource for you to
COVID-19 measures and write-downs on receivables by financial institutions, back to deductibility issues raised during the financial crisis?
Following the measures taken by the various governments in Belgium and abroad to fight against the spread of the Covid-19, it can be expected that credit institutions take write-downs on receivables. In this respect, the Belgian tax authorities have published a circular on this topic earlier this week. In a nutshell, the tax authorities have
Belgian transfer pricing audits: new wave initiated – Update
Our newsflash of 25 March 2020 informed you about the upcoming new wave of transfer pricing audits and the requests for information that were sent out. In the meantime, and in particular in light of the Covid-19 pandemie, we were informed that the BTA has suspended the sending out of the requests for information. For
COVID-19 #5 Cash repatriation
Although various listed groups have already announced to refrain from distributing dividends to their shareholders, centralising cash within the group is likely marked as a high priority item on every corporate agenda. Multinational groups may currently be revisiting their cash repatriation policy / advancing dividend distributions to get ahead trapped cash issues – e.g. arising
COVID-19 #4 Sale-and-lease-back to generate cash
Over the last week, we informed you about unexpected tax cash out effects from debt waivers, pitfalls relating to capitalising companies in financial distress and tax challenges of changing financing terms. As countries are preparing for longer lockdown periods then initially anticipated, it will not come as a surprise that many companies are trying to
Belgian transfer pricing audits: new wave initiated
Last week, the Belgian tax authorities have initiated a new wave of transfer pricing audits. Multiple taxpayers have already received or will receive in the next few days an in-depth questionnaire that focuses on their transfer pricing arrangements. The request for information on intercompany transactions and activities of the Belgian company or branch is the