Registration to the UBO register: extension of the deadline until 30 September
We already informed you about the introduction in Belgium of a register regarding the Ultimate Beneficial Owners (UBO’s) of legal entities. Initially, the information on the UBO’s needed to be registered by 30 November 2018. However, the deadline had been extended till 31 March 2019 by the Federal Public Service Finance (FPSF) taken into account
Upcoming due date for electronic filing of BEPS 13 related documents: 28 February 2019
Transfer pricing documentation has become an integral part of the compliance obligations of Belgian entities. The deadlines, criteria and formalities should therefore be followed up closely. Please find below a short summary of the obligations to be complied with by 28 February 2019. What? Belgian entities – if they meet certain criteria – have to
2019 implementation of Belgian 30% EBITDA rule approved
On 31 January 2019, the Chamber approved the advancement of the implementation date of the new interest limitation rule (30% EBITDA rule). The law will become effective after it is signed by the King and published in the Official Gazette. Concretely, this means that the Belgian 30% EBITDA rule will enter into force retroactively as from
Negative ruling highlights pitfalls of pre-deal carve-outs through partial demergers
In a recent decision, the Belgian ruling office rejected a pre-deal carve-out of real estate through a tax neutral partial demerger followed by a tax exempt transfer of shares of the operating company. Though the ruling does not particularly divulge novel views, it has the merit of highlighting common pitfalls related to these type of
The UBO-register: time to take action
As already discussed in our previous newsflashes (20 August 2018 & 28 September 2018), a register regarding the Ultimate Beneficial Owners (‘UBO’s’) of legal entities was introduced in Belgium. In principle, the information on the UBO’s needed to be registered by 30 November 2018. However, an extension of the deadline till 31 March 2019 was
15 January 2019 – Brexit Update – Brexit deal voted down!
Today, the UK’s House of Commons voted on Mrs. May’s Brexit deal. As widely expected, the Brexit deal was voted down. Although it’s still unclear what’ll happen next, the voting down of the deal requires that Mrs. May come back to the House of Commons with an alternative motion by next Monday, opening a door
Belgian tax reform – Recap of corporate income tax measures applicable from 1 January 2019
A new year typically entails new tax measures. Below you will find a brief overview of some important Belgian corporate income tax measures that have entered into force, or are expected to enter into force, in 2019 (as part of the second phase of the Belgian tax reform). For a detailed overview of the measures,
Foreign real estate funds eligible for Dutch FBI tax exemption
On 23 November 2018, the Lower Court in Breda, the Netherlands, decided that a German Open-Ended Public Fund (represented by PwC) was entitled to the FBI regime providing, among others, for a 0% Corporate Income Tax (CIT) rate on Dutch source real estate income. The Court also ruled that the portfolio investment test (one of
