Circular letter 2025/C/49 confirms the right to a first-time filing error without penalty
On 28 July 2025, the Belgian tax authorities issued a circular letter, providing guidance on the amendments to Article 444 of the Belgian Income Tax Code (WIB 92) introduced by the Programme Law of 18 July 2025. The revised rules, applicable to tax assessments issued from 29 July 2025 onwards, introduce a rebuttable presumption of
Wage withholding tax exemption – New circular letter provides an update on the partial wage withholding tax exemption for night and shift work
Context On 31 July 2025, the Minister of Finance released a long-anticipated circular letter detailing significant updates to the partial wage withholding tax exemption for night and shift work. The introduction of the Bis Variant, coupled with recent case law, contributed to increased complexity, and varied interpretations of certain regulations, leading to uncertainty among applicants.
Belgian Government Summer Agreement – 21 July 2025
On 21 July 2025, the Belgian government reached a summer agreement to implement reforms in the fields of pensions, the labour market, healthcare, and income tax. This agreement needs to be incorporated into draft legislation, which still requires approval through the legislative process. A high-level summary of the envisaged measures in the fields of
One step closer to finalising the CBAM and the EU ETS revision
Last week, the European Parliament (EP) and the Council reached a provisional agreement on the Carbon Border Adjustment Mechanism (CBAM) on 13 December, and later on 17 December on the revision of the EU Emission Trading System (ETS). These agreements represent an important milestone in the extension of the EU carbon market and the implementation
New provisions grant judicial police powers to Belgian tax inspectors to combat fraud
The law of 17 March 2022 regarding various fiscal provisions to combat fraud has recently been published and adopted. It includes new tax provisions that remove the existing legal obstacles for officials of the Belgian tax administration to participate in judicial investigations. This law provides for a new legal framework that allows designated tax authority officials to
National courts to interpret milestone EU Danish cases on beneficial ownership and abuse
On 26 February 2019, the Court of Justice of the European Union (CJEU) issued its judgments in the so-called “Danish cases”. The underlying question of these cases was whether dividend and interest payments could be exempt from withholding tax under the EU Parent Subsidiary and Interest & Royalty Directives, when the payments were made from
Tax dispute resolution – Belgium obtains positive peer review on its Mutual Agreement Procedure practice
Background Improving dispute resolution mechanisms as regards the application and interpretation of tax treaties is high on the agenda of the OECD and a number of countries. Under BEPS Action 14, there is a broad commitment to implement a minimum standard to strengthen the effectiveness and efficiency of Mutual Agreement Procedures (“MAP”). One of the
Belgium implements new EU Tax Dispute Resolution Directive
On 2 May 2019, Belgium completed the implementation process of the Directive on tax dispute resolution mechanisms in the EU (Council Directive 2017/1852 of 10 October 2017). This enhanced procedure for resolving cross-border direct tax disputes puts taxpayer rights at the forefront, has a broader scope of application as well as an obligation for the
