Conflicting Belgian case law on transfer of excess interest deduction capacity – EU court to decide
The application of the 30% EBITDA interest limitation continues to give rise to significant uncertainty in Belgian acquisition structures. This uncertainty has now been elevated to EU level, as the court of first instance of Walloon Brabant has decided to refer a prejudicial question to the Court of Justice of the European Union. Under the
Investment deduction certificate – application deadline to be postponed
Further to our previous updates on the thematic investment deduction (see our newsflash of 16 January 2025 and our newsflash on the Royal Decree of 28 July 2025), the Flemish region recently announced on its website that an additional extension to the deadline for submitting certificate applications will be granted. This is, however, still subject to formal enactment by Royal Decree. Taxpayers must obtain a certificate
Tax bites podcast – Transfer Pricing audits
New Tax Bites episode out now! Pieter sits down with transfer pricing experts Ann and Brecht, and legal expert Véronique, to explore the changing Belgian TP audit landscape. Discover what happened to the traditional February audit “wave”, how audits are evolving and which companies and topics are being targeted. Get practical tips on prevention, managing
Advance tax payments for assessment year 2027: mind the surcharge
Belgian companies/branches have the possibility (but not the obligation) to make advance tax payments during the financial year. If corporate taxpayers do not make sufficient advance tax payments, a tax surcharge of 6.75% will be applied on the amount of Belgian corporate income tax due (upon assessment) which is not covered by advance tax payments. It is therefore strongly recommended to ensure that sufficient advance tax payments are made timely to avoid or minimise this surcharge. Corporate
2026 compliance timeline – Key deadlines
With regulatory expectations continuing to tighten, staying compliant on time is more important than ever. Organizations face increasing pressure to meet key deadlines, making effective planning essential. To support you in navigating the year ahead, we are pleased to share a non‑exhaustive compliance timeline for 2026. This overview brings together the most important (in)direct tax and statutory accounting obligations, helping you anticipate what’s coming and stay well‑prepared throughout the year.
Tax bites podcast – International Tax Strategy for 2026: Aligning global tax policy changes with business operations
This podcast covers key points from our 6 February 2026 international tax webinar, including the Side‑by‑Side Package, updates on trade and tariffs, work mobility, and changes to the OECD Commentary. We also discuss expectations for 2026. If you’re interested in learning more or accessing the full webinar recording, please contact one of the presenters. Listen here: https://www.pwc.be/en/services/tax-and-legal/tax-bites-podcast-series/episode-62-international-tax-strategy-for-2026-aligning-global-tax-policy-changes-with-business-operations.html About the speakers
Belgium issues administrative clarification regarding the new form 275 CBC NOT
On 27 January 2026, the Belgian tax administration released updated guidance on the interpretation of the amended Country-by-Country Notification (“CbC Notification”) requirements (Form 275 CBC NOT). This follows the introduction of the amended Form 275 CBC NOT earlier in 2024 (New Royal Decree of 16 June 2024). As a reminder, all Belgian constituent entities within multinational enterprise (MNE) groups must submit a CbC Notification if the MNE group is subject
BIC Transition Impact: final opportunity to validate (late) December 2025 advance tax payments by 31 January 2026
Following a new public contract, BNP Paribas Fortis took over all federal government accounts from Bpost during the weekend of 13–14 December 2025. As a consequence: account numbers (IBAN) remain unchanged (identifiable by digits 679 in positions 5–7). as from 15 December 2025, international payments must use the new BIC: GEBABEBB. Impact on
