Upcoming changes to the Belgian transfer pricing documentation forms
Transfer pricing documentation has become an integral part of the compliance obligations of Belgian entities since financial year 2016. A Belgian company (or a branch) that is a part of a multinational group will have to submit the form 275 LF (Local file) and the form 275 MF (Master file) in case one of the following
Belgian Tax Authorities publish additional (and much welcomed) guidelines in view of the Co-Operative Tax Compliance Programme and details on what they consider to be a “mature” Tax Control Framework (TCF)?
Flashback to 2018 – What is the CTCP? With its launch in 2018 and with the ultimate goal of (i) achieving faster legal certainty for companies and (ii) improving compliance with tax obligations, the Belgian Co-operative Tax Compliance Programme (CTCP) introduced a mindshift, from a reactive tax audit modus to a collaborative, proactive approach based
Belgian law amending the investment deduction and innovation income deduction regime published in the Official Gazette
On 29 May 2024, the law of 12 May 2024 containing various tax provisions was published in the Belgian Official Gazette. This law implements several changes to the regime of the investment deduction and the innovation income deduction (IID). Key features of the new legislation are summarized below. For more information, we refer to our
New withholding tax exemption for variable shifts adopted in Parliament
On 3 May 2024, the Belgian Parliament adopted the law concerning the new exemption of withholding tax for shift work with variable shifts. The law introduces the “variant bis”, aiming to ensure clarity and legal security, mitigating recent judicial decisions that restricted the definition of qualifying shift. For more information, we refer to our previous
Belgian draft law amending the investment deduction and innovation income deduction regime
On 29 February 2024, a draft law was submitted covering (amongst others) the investment deduction regime. The proposed changes to the investment deduction included in the preliminary draft law have largely been retained in the draft law submitted by the Belgian government to parliament (see also our newsflash of 14 November 2023). The following items
Belgian draft law amending the law introducing a minimum tax for multinational companies
On 6 March 2024, the Belgian government submitted a draft law to parliament, which is intended to amend the law of 19 December 2023 on the introduction of a minimum tax for multinational companies and large domestic groups. If the draft law is approved, it would be applicable to financial years starting on or after
Advance tax payments: Mind the significant increase of the surcharge
A surcharge is due on the final amount of Belgian corporate income tax payable upon assessment in case a company doesn’t settle its Belgian corporate income taxes due by means of timely advance tax payments during the financial year concerned. Please be advised that the global surcharge will be increased to 9% for assessment year
OECD issues a new package of Administrative Guidance on Global Anti-Base Erosion Model Rules (Pillar 2)
On 18 December 2023, the OECD released the third package of Administrative Guidance. This third package follows the Administrative Guidance released in February and July. This guidance provides welcome clarification to the Pillar 2 rules, which will in many territories, including Belgium, come into force as from financial year 2024, The document addresses issues and
