News articles written by Grégory Jurion

Foreign real estate funds eligible for Dutch FBI tax exemption

20 December 2018

On 23 November 2018, the Lower Court in Breda, the Netherlands, decided that a German Open-Ended Public Fund (represented by PwC) was entitled to the FBI regime providing, among others, for a 0% Corporate Income Tax (CIT) rate on Dutch source real estate income. The Court also ruled that the portfolio investment test (one of

Update on pending changes to the German RETT regime for share deals

25 June 2018

The heated debate on the tightening of the German RETT Act to expand the scope of this tax to include sales of less than 95% of the company’s share capital continued with a meeting of the Finance Ministers of the Federal States on 21 June 2018. Although no formal draft document is available yet, changes

President Trump signs Omnibus Spending Bill with Favorable Real Estate Tax Provisions

9 April 2018

On 23 March 2018, President Trump signed the Consolidated Appropriations Act of 2018 (the Omnibus Act), an omnibus government spending bill which includes several technical corrections of previously enacted tax provisions related to FIRPTA, REIT spin-off transactions, REIT income tests and the partnership audit rules. The Omnibus Act also includes new low-income housing tax credit

New Double Tax Treaty between France and Luxembourg: impact on real estate structures

23 March 2018

On March 20, the Luxembourg and French Governments have signed, amongst other, a new double tax treaty (DTT), together with an accompanying Protocol. The new DTT seeks to modernise the rules applying. The current treaty between Luxembourg and France was signed as long ago as 1 April 1958. The new DTT is fully “post-BEPS”. It

Belgian tax reform: impact on the real estate industry

27 July 2017

Yesterday, the Belgian government reached an agreement on several tax measures, including a corporate tax reform and the introduction of an option to apply VAT on immovable letting.  Although these measures will be developed further in detail in the coming months, it is already certain they will have an important impact on the Belgian real