Belgian tax reform: impact on M&A
The Belgian government has reached an agreement on an important tax, economic and social reform package. The contemplated changes aim to boost the Belgian economy through an investment friendly climate, but could also significantly impact deal structuring and due diligence processes. The highlights of the contemplated tax reform are the gradual reduction of the Belgian corporate
Amendments to the Parent-Subsidiary Directive implemented under Belgian tax law
On 1 December 2016, a Bill was published in the official Belgian Gazette implementing into Belgian tax law two amendments to the Parent-Subsidiary Directive. The first amendment to the Parent-Subsidiary Directive aims at tackling situations which would result in ‘double non-taxation’ by introducing a rule against hybrid instruments. Under this new rule, dividends received by
New double tax treaty signed between Belgium and Japan
On 12 October 2016, the new Belgium-Japan Income Tax Treaty was signed in Tokyo during the Belgian economic mission. Once in force and effective, the new treaty will replace the old Belgium-Japan Income Tax Treaty (1968) as amended by the protocols signed in 1998 and 2010. The treaty will enter into force 30 days after
PwC’s Brexit monitor
The referendum result on Brexit has not only led to economic and political uncertainty within the UK, but also on mainland Europe. The final impact of Brexit is yet unknown, but will certainly weigh down on our economy, business activity and financial markets. You may find the following PwC Brexit Monitor on the subject matter interesting.
Lost in Transactions – Your one-stop guide for everything you need to know about BEPS and M&A
We are pleased to announce that M&A Tax & Legal Services just finalised a publication which will guide you in everything you need to know about BEPS and M&A. ‘Lost in transactions’ is a practical guide to managing M&A deals in today’s global, digital world. Please find more information and the PDF version of the
The Rulings Commission publishes ruling request templates
The Belgian Rulings Commission has recently published ruling request templates. These templates have been prepared in an effort (i) to facilitate access to tax rulings and (ii) for transparency purposes. Ruling request templates have been made available in Dutch and in French for the following relevant transactions: Mergers, Partial demergers, Contribution of a line of
Fund structuring – Impact of BEPS
One of the most important decision-making factors that an asset manager (General Partner – GP) considers in setting up a fund is to ensure that the investment structure is tax neutral for its investor (Limiter Partners – LPs) and provides for the most reliable regulatory framework. The complexity of setting up international investment vehicles pooling
Management exit considerations: capital gains tax treatment
Retaining and incentivising the management of portfolio companies is key for private equity firms. Managers will thus invest alongside with investors and enter into some incentive arrangements. At a future exit, they may then expect to walk away from their investment with a significant return. Belgian managers may invest through a personal holding company or
