Belgian implementation of the UBO register
As mentioned in our previous newsflash of 19 July 2017, according to the fourth Anti-Money Laundering Directive (2015/849), adopted by the European Parliament on 20 may 2015, one of the obligations of all EU Member States was to establish a national register of ultimate beneficial owners (UBO) before 26 June 2017. Through the introduction of this
Innovation Income Deduction: FAQ published
The Belgian Tax Authorities have published a long awaited list of Frequently Asked Questions (FAQ) with respect to the Innovation Income Deduction (IID). Under this regime, Belgian taxpayers can deduct 85% of qualifying net innovation income from their corporate income tax basis. The FAQs are available in Dutch and French. This publication is important as
Summer deal advances the implementation of the Belgian EBITDA rule by one year
In the context of its comprehensive political agreement reached last week, the Belgian Government decided to advance the implementation of the new interest limitation rule from 2020 to 2019 (i.e. financial years starting on or after 1 January 2019). The new Belgian interest limitation rule is the transposition of the EBITDA-based interest limitation rules included by
Expected changes in employers’ tax reporting obligations of some equity incentives
When foreign headquartered companies grant stock options to employees of their Belgian subsidiaries, such option grants, where taxable at grant, are ALWAYS reportable by the Belgian employing subsidiary on the employee’s individual statement 281.10. This reporting obligation is due irrespective of whether such subsidiary is involved in the option grant or expenses the stock option
Last steps in the Belgian corporate tax reform taken before the summer recess
Just before the holiday period, the Belgian Chamber adopted the final text of the corporate tax reform that was initiated last year. As expected, a new Act amends and supplements the Corporate Income Tax Reform Act and the Program Act, both published end of December 2017. Some of the very last changes introduce new anti-abuse
OECD publishes long-awaited public discussion draft on the transfer pricing aspects of financial transactions
On 3 May 2018, the OECD published a long-awaited public discussion draft on the transfer pricing aspects of financial transactions. With this publication, the OECD has reached another important milestone in the BEPS saga. As all groups have such transactions, the importance of the discussion draft cannot be underestimated. The discussion draft has been developed
OECD publishes (long awaited) additional guidance on hard-to-value intangibles and profit split methods
In view of landing on the Transfer Pricing track in its work to curb Base Erosion and Profit Shifting (BEPS Actions 8-10) the OECD published two new reports on 21 June 2018: Guidance for tax administrations on the application of the approach to hard-to-value intangibles; and Revised guidance on the application of the profit split
EU Commission finds that Luxembourg gave State aid to GDF Suez (now Engie)
On 20 June 2018 the European Commission (“EC”) issued a press release concerning its final decision in the State aid investigation into tax rulings granted by the Luxembourg tax authorities to GDF Suez group (now Engie) (“the Group”) in relation to the treatment of certain financing transactions. The EC considered that the Group received an
