Anti-Tax Avoidance Directive Webcast Series Episode Two: Netherlands and Italy Thursday, 28 February 2019, 15:00 – 16:00 CET
We are pleased to inform you of the next episode of our Anti-Tax Avoidance Directive Webcast Series, Episode 2: Netherlands and Italy. The EU Anti-Tax Avoidance Directive (ATAD I & II “ATAD”) is designed to tackle tax avoidance practices, and creates minimum standards for EU Member States, which may require changes to corporate tax laws.
European Court annuls the decision of the European Commission that Excess Profit rulings are State Aid
The General Court decided that the European Commission has made an error in its decision where it concluded that the Belgian excess profit regime resulted in a so-called ‘State aid scheme’. As a result of this approach under a State aid scheme (rather than assessing each of the rulings involved), the European Commission limited its
Circular 2019/C/14 – Addendum to the circular 2017/C/56 containing additional guidance on the transfer pricing documentation penalty regime
On 8 February 2019, an addendum to the circular was issued containing additional guidance on the transfer pricing documentation penalty regime. General All companies and permanent establishments must prepare transfer pricing documentation unless they meet certain thresholds for exemption from filing documentation. Failing to file (in due time) the transfer pricing documentation (i.e. country-by-country report
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
