The law of 17 March 2022 regarding various fiscal provisions to combat fraud has recently been published and adopted. It includes new tax provisions that remove the existing legal obstacles for officials of the Belgian tax administration to participate in judicial investigations. This law provides for a new legal framework that allows designated tax authority officials to
Investigation period for direct taxes soon prolonged without distinction between an ordinary investigation and a fraud investigation?
A legislative proposal has been submitted to the Belgian Parliament with a view to harmonising the investigation and assessment periods for income tax and VAT. The proposal primarily looks to amend the legal provisions relating to the investigation period for direct tax matters. Currently, the normal investigation period for income tax is 3 years. This
The European Commission (EC) has recently published guidelines on the European Trust and Cooperation Approach (ETACA), a pilot project on cooperative compliance within the EU specifically focusing on transfer pricing risks for large multinationals. The ETACA pilot was already announced in the Action Plan for fair and simple taxation supporting the recovery strategy (see also
Tax authorities around the globe are heavily engaged in tax audits, with pressure being exerted on tax enforcement and collection processes. Joint audits and international exchange of information is fueling complexity with each country varying in its focus areas, approach and dispute resolution processes. How our Tax Controversy Solutions can help? The PwC Tax Controversy
During the outbreak and spreading of the COVID-19 pandemic, many businesses faced or are facing significant cash flow constraints, disruption to their supply chains, or even forced (temporary) closing for business. The long-awaited OECD guidance on the transfer pricing implications of the COVID-19 pandemic was finally published on 18 December 2020. A plea for practical
Taxpayer relationship and tax audits in Belgium: what can we expect following the Belgian Minister of Finance’s policy note?
The Belgian Minister of Finance, Vincent Van Peteghem, has made his first official statements on the ambitions of the new government De Croo I in relation to the SPF/FOD Finance. Minister Van Peteghem, also in charge of the Coordination of the Fight against Fraud, presented his policy note on 4 November 2020 to the Belgian
The recent developments in the international tax world are clearly finding their way into the Belgian tax investigation practice. PwC observes a significant increase in tax audits in which the Belgian tax authorities are focusing on passive income flows (dividend, interest and royalty) and alleged tax abuse through the involvement of intermediary entities. A number
Tax dispute resolution – Belgium obtains positive peer review on its Mutual Agreement Procedure practice
Background Improving dispute resolution mechanisms as regards the application and interpretation of tax treaties is high on the agenda of the OECD and a number of countries. Under BEPS Action 14, there is a broad commitment to implement a minimum standard to strengthen the effectiveness and efficiency of Mutual Agreement Procedures (“MAP”). One of the