Tax audits are picking up – But the wave is over
The era of the large-scale tax audit “wave” in February is over. Tax audits in Belgium are increasingly spread throughout the year, and they are becoming more targeted, data-driven and multidisciplinary. Here’s what you need to know. What’s behind the yearly uptick? The Belgian Tax Authorities (BTA) have moved away from the traditional model of launching large-scale, sometimes announced, thematic audit campaigns – including in transfer pricing (TP). February and March do, however, typically still bring a visible uptick in
EUDR Newsflash: Compliance will be won or lost at the border
The recent EU vote, held just before the winter holidays and only days before the original go-live date, has resulted in a further 12-month deferral and a significant refocus for EUDR compliance. The border is now the central control point, placing importers firmly in the spotlight. The core objective of the law has not changed
Simplified side stream mergers – new law clears hurdles for ‘real’ tax neutrality
On 16 June 2023, the ‘simplified side stream merger’ (vereenvoudigde zusterfusie / fusion simplifiée entre soeurs) was introduced in the Code of Companies and Associations and in the Income Tax Code. However, even in case all conditions were fulfilled, the transaction could not entirely take place tax neutrally due to ‘imperfections’ in the corporate income
Tax Bites Podcast – Navigating shifts in global tax policy: Implications for businesses
In this after‑event podcast we discuss the origin of our international tax webinar series and distill the key takeaways of the last edition (23 – 25 September 2025). We highlight, and reflect on, recent developments such as the G7 side‑by‑side approach, the EU’s long‑term budget and own resources, EU‑US trade negotiations, the UN meetings on
General filing extension until 8 October 2025 confirmed for corporate income tax, non-resident corporate income tax, and legal entity tax returns
The Minister of Finance has announced a general extension of the filing deadline for tax returns that were originally due between 30 September and 7 October 2025. These returns should now be submitted by 8 October 2025 at the latest. This extension applies to: Corporate income tax Non-resident corporate income tax Legal
Belgium’s Inpatriate Tax Regime: Transitional amendment allows retroactive access for certain 2025 starters
In a competitive labour market, the inpatriate tax regime plays a crucial role in attracting international talents. The draft law containing various tax provisions is set to make the expat regime more appealing, with the following main changes expected to take effect for remunerations paid or attributed from 1 January 2025: Increased tax-free allowance: The
Arcomet case: When TP adjustments trigger VAT
Introduction The interaction between transfer pricing and VAT has long been recognised as complex. Transfer pricing rules are designed for corporate income tax, while VAT is an indirect tax based on consumption, making alignment between the two systems difficult. Both the VAT Committee and the VAT Expert Group have acknowledged these challenges. The general principle
Antwerp Court of Appeal rules capital gains on carry shares from option exercises as non-taxable income
On 25 February 2025, the Antwerp Court of Appeal confirmed that capital gains on shares – issued by Co-Investment Vehicles (CIVs) – embedding a carried interest and acquired following the exercise of options that were taxable at grant are not taxable as miscellaneous income (art. 90 1° ITC 92 and 90 9° ITC 92) (2023/AR/1737).
