Expected change in Belgian CFC regime
A draft law was introduced into parliament to change the Belgian CFC regime, which was introduced as part of the EU Anti-Tax Avoidance Directive (hereafter “ATAD directive”) in 2017. The CFC regime Belgium introduced back in 2017 taxed non-distributed income arising from non-genuine arrangements which have been put in place for the essential purpose of
Mid-summer tax update
As we reach mid-summer, it’s time to do a short wrap-up of some of the recent tax developments to keep you up to date in this ever-changing tax landscape. In this update we will cover the following topics: Council of Ministers accept the Belgian implementation of the Public CbCR Directive Belgian Parliament considers bill to
PwC’s Pillar Two Country Tracker
PwC has recently launched the Pillar Two Country Tracker, a tool designed to track the status of the implementation of Pillar Two around the globe. Specifically, Pillar Two focuses on the introduction of a global minimum Effective Tax Rate (ETR) applicable to multinational groups with consolidated revenue of over €750 million. Such groups will be
Russia, the British Virgin Islands, Costa Rica and the Marshall Islands added to list of non-cooperative jurisdictions for tax purposes
On 14 February 2023, the EU Council’s Code of Conduct Group formally decided to add Russia, the British Virgin Islands, Costa Rica and the Marshall Islands to the EU list of non-cooperative jurisdictions for tax purposes (also referred to as the ‘EU tax haven blacklist’). The EU tax haven blacklist now includes 16 countries: American
PwC’s Tax Bites podcast: OECD issues Administrative Guidance on Pillar 2
In this episode, we discuss our first impressions of the 111-page Administrative Guidance on Pillar 2 published by the OECD on Thursday, 2 February 2023. A wide range of issues related to the GloBE Rules and Commentary were addressed in the guidance, and our experts also welcomed the additional clarification and examples, including those on
OECD issues Administrative Guidance on Global Anti-Base Erosion Model Rules (Pillar 2)
On 2 February 2023, the OECD released the long-awaited Administrative Guidance on the Pillar 2 Model Rules. The GloBE Rules and Commentary consist of a coordinated system of rules designed to ensure that large MNE Groups are subject to a minimum effective tax rate of 15%. This set of rules are also to be implemented
Formal adoption of the EU Directive on ensuring a global minimum level of taxation
What has happened? The EU Member States have reached an agreement to implement Pillar 2 to ensure a global minimum taxation for large groups. Political support is confirmed now that Pillar 2 has been enshrined legislatively in an EU Directive which was adopted unanimously by all EU Member States. The Directive should be implemented into
Hungary lifts veto on Pillar 2 – Council reaches unanimity
Last night the EU Council reached an agreement to implement Pillar 2 (press release) after Hungary dropped its veto on the matter. The next step is to start the written procedure and to publish the Pillar 2 Directive in the Official Journal of the EU. The envisaged timeline to implement Pillar 2 into domestic
