OECD Secretariat seeks input on global minimum tax design
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
OECD publishes proposal to rewrite international profit allocation rules
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.
Circular Letter regarding the “grandfathering” provision included in 30% EBITDA rule
On 11 September 2019, the Belgian tax administration published a Circular Letter regarding the grandfathering provision that is included in the recently introduced interest deductibility limitation (i.e. 30% EBITDA rule). The 30% EBITDA rule includes a grandfathering provision for loans that have been issued before 17 June 2016 and that have not been “fundamentally modified”
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
Corrections to previously filed CbC Reports
On July 30th 2019, the Belgian Tax Authorities (“BTA”) communicated that the portal MyMinfin has been opened for the submission of corrections to Country-by-Country Reports (“CbCR”) filed in previous years. In addition, the BTA have published practical guidelines and examples for reporting entities on how to report these corrections to previously filed CbCR. These guidelines
Belgian Ratification of the MLI: Ratification document deposited at OECD on 26 June 2019
On 6 June 2019, the legislative documents implementing the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (also known as the MLI) were finally approved by all six legislative authorities in Belgium. The Belgian law ratified the full application of the MLI and its Explanatory Note, the reservations and notifications made by
Fundamental changes to international tax structure ahead following OECD project on digitalisation of the economy
On 31 May 2019, the 129 members of the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting (BEPS) released a Programme of Work to develop a consensus solution to the tax challenges arising from the digitalisation of the economy. The Programme of Work was endorsed at the G20 meeting of finance ministers in Japan
Belgian Ratification of the MLI: a Game Changer in the International Tax Field
On 6 May 2019, the legislative documents implementing the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (also known as the MLI) was finally approved by all 6 legislative authorities in Belgium. The Belgian law ratified the full application of the MLI and its Explanatory Note, the reservations and notifications made by
