Circular letter on the Belgian CFC rules (Circular Letter 2024/C/82 December 13, 2024)
On 13 December 2024, the Belgian tax authorities issued a circular letter (Circular Letter 2024/C/82 December 13, 2024) regarding the new Belgian Controlled Foreign Corporation (CFC) regulations and a circular letter (Circular Letter 2024/C/83 December 13, 2024) regarding changes from a tax procedural perspective. Almost one year ago, the program law of 22 December 2023
OECD issues a fourth package of Administrative Guidance on Global Anti-Base Erosion Model Rules (Pillar 2)
On 17 June 2024, the OECD released the fourth set of Administrative Guidance on GloBE rules, with the intention of clarifying the operation of these rules. This package follows the Administrative Guidance sets released in February, July and December last year. It is the first package of Administrative Guidance following the publication of the Consolidated
Belgian law amending the investment deduction and innovation income deduction regime published in the Official Gazette
On 29 May 2024, the law of 12 May 2024 containing various tax provisions was published in the Belgian Official Gazette. This law implements several changes to the regime of the investment deduction and the innovation income deduction (IID). Key features of the new legislation are summarized below. For more information, we refer to our
Belgian draft law amending the investment deduction and innovation income deduction regime
On 29 February 2024, a draft law was submitted covering (amongst others) the investment deduction regime. The proposed changes to the investment deduction included in the preliminary draft law have largely been retained in the draft law submitted by the Belgian government to parliament (see also our newsflash of 14 November 2023). The following items
Belgian draft law amending the law introducing a minimum tax for multinational companies
On 6 March 2024, the Belgian government submitted a draft law to parliament, which is intended to amend the law of 19 December 2023 on the introduction of a minimum tax for multinational companies and large domestic groups. If the draft law is approved, it would be applicable to financial years starting on or after
OECD issues a new package of Administrative Guidance on Global Anti-Base Erosion Model Rules (Pillar 2)
On 18 December 2023, the OECD released the third package of Administrative Guidance. This third package follows the Administrative Guidance released in February and July. This guidance provides welcome clarification to the Pillar 2 rules, which will in many territories, including Belgium, come into force as from financial year 2024, The document addresses issues and
Belgian Federal Government approves law introducing a minimum tax for multinational companies (Pillar 2)
Yesterday, on 14 December 2023, Belgium approved the final law introducing a minimum tax for multinational companies and large domestic groups. This is the Belgian transposition of Council Directive (EU) 2022/2523 of 15 December 2022 ensuring a global minimum level of taxation for groups of multinational enterprises and large domestic groups in the European Union.
Belgium and The Netherlands agree on employees working from their home location
On November 23, 2023, the Competent Authorities (CA) of Belgium and The Netherlands signed an agreement* clarifying when a permanent establishment (PE) exists for the employer in the other country if employees are working from their home location in that other country. This agreement provides welcome additional guidance on the cases in which an employee
