The General Court considers the Belgian Excess Profits Ruling to be unlawful State Aid
On 20 September 2023, the General Court of the European Union (GCEU) ruled for the second time in the case of the Belgian Excess Profits Ruling (Belgian EPR) (Judgement of the General Court, 20 September 2023, in case T-131/16 RENV). Contrary to its first decision in 2019 on EPR as a “scheme”, it now confirmed
German- Belgian Colloquium on global tax reform: a status update on the OECD Two Pillar Approach
On May 23rd, 2022 the Belgian and German tax authorities organized a colloquium on the two-pillar approach. The colloquium was held in Brussels and was hosted by Mr Hans D’Hondt, Chairman of the Management Committee of the Belgian Federal Public Service Finance. The colloquium was opened by Mr D’Hondt and Mr Martin Kotthaus, Ambassador of
December 20 OECD/G20 Pillar 2 GloBE Model rules
A ten minutes tour of: The introduction of a global minimum taxation of 15% Some salient new points, such as inclusion of deferred taxes to calculate jurisdictional ETR The importance of modeling to understand the impact The ambitious timeline for implementation Earlier today, the OECD published the long awaited Global Anti-Base Erosion Model Rules (Pillar
G7 commits to a global minimum tax of at least 15% and taxation of digitalised economy
The G7 finance ministers published on 5 June 2021 a Communiqué announcing that they reached a high-level political agreement on a global tax reform. In particular, they agreed on the reallocation of a share of the profits of certain multinational enterprises to market jurisdictions (Pillar 1) and a global minimum tax of at least 15%
Tax Bites Podcast – EU Business Taxation Roadmap
EU Roadmap for Business Taxation: EU Dynamite? On 18 May 2021, an important development in EU Tax policy took place when the European Commission announced their roadmap for Business Taxation for the 21st Century. This roadmap, published today, outlines 5 actions that the European Commission proposes to take in the coming months in Europe (some
The OECD published its blueprints on pillar 1 and 2 – get the latest insights via our webcast.
The OECD released ‘Blueprints’ on the tax digitalisation/globalisation project on Monday 12 October. These two Blueprints cover Pillar 1 and Pillar 2 in the project framework previously announced. Pillar 1 looks at the attribution of revenues to market jurisdictions. Pillar 2 deals with the imposition of a minimum tax. The Blueprints indicate the degree of
The impact of COVID-19 on routine profits
Evidencing downward adjustments for limited risk entities commands more than a quick browse through high-level macroeconomic trends. As many companies consider to adjust their transfer pricing (TP) policies as a result of the current economic situation, we’ve performed a robust macroeconomic analysis linked to some 180,000 company data points. The approach is rooted in work
OECD publishes (long awaited) additional guidance on hard-to-value intangibles and profit split methods
In view of landing on the Transfer Pricing track in its work to curb Base Erosion and Profit Shifting (BEPS Actions 8-10) the OECD published two new reports on 21 June 2018: Guidance for tax administrations on the application of the approach to hard-to-value intangibles; and Revised guidance on the application of the profit split
