Impact of announced tax measures on Transfer Pricing
As previously announced, a number of new tax measures has been announced in the framework of the Belgian government formation and the budget for 2015. Some of these will also have an impact on transfer pricing: The plan is to invest heavily in data mining tools for case selection purposes. These are likely to be used for
New Belgian tax measures announced
A number of new tax measures have been announced in the framework of the Belgian government formation and the budget for 2015, on which an agreement was reached in the second week of October 2014. These measures have an impact on: – entities – companies – corporate income tax; – individuals – personal income tax;
Note to debtors of payroll tax for payments to non-residents (section 228, § 3 BITC or so-called ‘catch-all provision’)
On 23 July 2014, the Belgian Central Tax Administration published a note to the debtors of payroll tax for payments to non-residents in the Belgian Gazette, which provides for some welcome clarifications. Background Following the Miscellaneous Provisions Act of 13 December 2012 (published in the Belgian Official Gazette on 20 December 2012) and the Royal
VAT: Practice note – Retention of documents
The Belgian Income Tax and VAT authorities recently published a combined practice note commenting on the alignment of the Income Tax and VAT procedures as regards the retention of documents. What is new for VAT is the fact that the delivery of a receipt in case of retention of documents by the VAT authorities is
The 6th State Reform and Belgian expatriate tax
On 28 May 2014 the law of 8 May 2014, modifying the Belgian income tax code of 1992 following the 6th State Reform (Act of 6 January 2014) was published in the Official Gazette. Rules applicable until tax year 2014 (income year 2013 included) Foreign executives temporarily working in Belgium for whom the special tax
6th State reform: Taxation of individuals – Changes published
On the 28th of May 2014 the law reforming the Belgian Income Tax Code in light of the 6th state reform has been published in the Official Gazette. Due to this state reform Regions (Flanders, Brussels and Wallonia) will obtain increased fiscal autonomy. A portion of the personal income tax will be attributed to the
Parliamentary question regarding the application of Belgian thin cap rules for cash pooling activities
The Minister of Finance answered a Parliamentary question on how the Belgian thin cap rules should be applied in practice to cash pooling activities. The Minister was asked a.o. how a daily assessment of the 5:1 debt-equity ratio links in with the netting of interest paid and received for cash pooling companies (for more information
Practice note issued in relation to Belgian fairness tax
As from AY14 (which are financial years ending 31 December 2013 or later), a so called ‘fairness tax’ of 5.15% is levied on certain dividend distributions made by large Belgian companies or by foreign companies with a Belgian permanent establishment, when the underlying profits have not been effectively taxed due to tax losses or Notional
