Pillar 2 rules in an M&A context: time for action!
The OECD’s Pillar 2 rules have introduced a global minimum effective taxation of 15% for multinational enterprises or large domestic groups. Urgent action should be taken by all groups subject to the new mandatory pillar 2 notification, which is due by 13 July 2024. But also in transactions, the potential impact of pillar 2 should
Recent changes to the Belgian CFC legislation can give rise to an increased tax burden of your investment
In case your Belgian company has a foreign participation which it controls and of which the effective tax rate is lower than 12.5%, based on the taxable profit of that foreign entity recalculated according to Belgian tax rules, an additional tax could arise on the undistributed passive income of the foreign participation. In other words,
Adapted tax provisions regarding ‘judicial reorganisations’ offer new opportunities… and challenges
Recent adjustments of tax provisions regarding ‘judicial reorganizations’ offer new opportunities and challenges for distressed companies and their creditors. Most of these adjustments, aligning tax law with the updated insolvency law, entered into force with retroactive effect to 1 September 2023. The law of 28 December 2023 containing various tax measures has adapted the tax
New ways to carving-out and integrating your business in Belgium not always tax neutral
In 2023, new ways of performing carve-out and integrating your business became possible from a legal perspective. Meanwhile the tax law has also been adapted to enable you to perform these new ways of reorganising your group structure tax-free. Nevertheless, still some problems remain and sufficient attention should be paid to the tax consequences of
Tax and Legal aspects of ESG in an M&A context – The deal Execution phase
In previous articles, we zoomed in on the importance of managing carefully the ESG (or at large “Sustainability”) hard and soft laws during the pre-deal phase of the M&A process. It was demonstrated that dealing/understanding the sustainability challenges during both the deal sourcing as well as the due diligence phase, actually contributes ultimately to
Possible important amendments to the stock option legislation and the introduction of a specific tax regime for free shares
A government proposal regarding new legislation with respect to stock options and stock plans was announced in the Belgian press last week (cf. please find the link to the entire article). It is however important to note that no texts are currently available and that it is currently not certain whether this proposal will eventually be
Possible important amendments to the stock option legislation and the introduction of a specific tax regime for free shares
A government proposal regarding new legislation with respect to stock options and stock plans was announced in the Belgian press last week. Below you can find a short overview of the proposed changes with some initial high-level reflections. It is however important to note that no texts are currently available and that it is currently
Tax and legal aspects of ESG in an M&A context – pre-deal phase
With the structural climate/sanitary reality and economic challenges, ESG (Environmental/Ecological, Social/Sustainable and Governance) has grown in importance for all stakeholders of an enterprise. So it’s no surprise that ESG has also become a hot topic in M&A projects and that Tax and Legal related ESG topics should be included in every step of a deal
