In order to address criticism of the European Commission on inter alia the Belgian implementation of the “EBITDA interest limitation rule”, the Belgian legislator has published new legislation to address those. This might impact the financing of real estate, entities that perform factoring activities or entities active in “long-term public infrastructure projects”. The scope of
Transfer pricing documentation requirements have become an integral part of the compliance obligations of Belgian entities and branches. The criteria, formalities and deadlines should therefore be followed up closely. Please find below a short summary of the obligations to be complied with by 31 December 2020. What? A Belgian entity or Belgian branch part of a
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
On 30 June 2020, the Belgian Tax Authorities published its Circular Letter 2020/C/88 containing an update of the Frequently Asked Questions (FAQ) (previous version dd. 4 May 2018) with respect to the Belgian transfer pricing documentation requirements on Country-by-Country Reporting (CbCR) (articles 321/1 to 321/2 BITC), the notification on CbCR (article 321/3 BITC), the Master
The recent developments in the international tax world are clearly finding their way into the Belgian tax investigation practice. PwC observes a significant increase in tax audits in which the Belgian tax authorities are focusing on passive income flows (dividend, interest and royalty) and alleged tax abuse through the involvement of intermediary entities. A number
Transfer pricing documentation has become an integral part of the compliance obligations of Belgian entities. The criteria, formalities and deadlines should therefore be followed up closely. Please find below a short summary of the obligations to be complied with by 31 December 2019. What? A Belgian entity part of a multinational group exceeding at least one
On 8 November, the Organisation for Economic Co-operation and Development (OECD) Secretariat published a Public consultation document: the Global Anti-Base Erosion Proposal (‘GloBE’) (Pillar II) which seeks stakeholders’ views on the introduction of common global minimum tax rules across the more than 130 countries participating in the OECD Inclusive Framework. Such rules would operate through top-up taxes
The proposal seeks to allocate a greater share of taxing rights to the countries where consumers/users are located – regardless of a business’ physical presence there.