CJEU judgment on compatibility of Dutch group taxation regime with EU fundamental freedoms
On 22 February 2018, the Court of Justice of the European Union (“CJEU”) issued its judgment in Joined Cases C‑398/16 and C‑399/16 X BV and X NV v Staatssecretaris van Financiën. These cases, which were referred to the CJEU by the Dutch Supreme Court in July 2016, relate to the consequences of the ‘per element’
Upcoming due date for the electronic filing of the Master file and the Country-by-country notification: 31 March 2018
For the first year of filing of the new transfer pricing documentation, the Belgian tax authorities have granted an administrative extension for the Master file and the Country-by-country notification till the end of March. What? A Belgian entity of a multinational group exceeding at least one of the following criteria needs to submit a Master
Belgian transfer pricing audits: increased manpower, new focus areas and enhanced cooperation on the horizon
Beginning in February of 2018, the Belgian tax authorities will initiate a new wave of transfer pricing (TP) audits. The central transfer pricing investigation team (TP Unit) is investing in additional manpower and changing investigation approaches to increase the effectiveness of audits. Taxpayers should also expect more scrutiny on TP matters from other tax departments,
Belgian corporate tax reform (substantively) enacted
On 22 December 2017, the Belgian Parliament has approved the Belgian tax reform bill. This bill has been published in the Belgian Official Gazette on 29 December 2017 and was signed by the Belgian King on 25 December 2017. Consequently, the Belgian tax reform has been substantively enacted for IFRS (IAS 12) on 22 December 2017
Belgian corporate tax reform enacted by Parliament
On 22 December 2017, the Belgian Parliament approved the major corporate tax reform announced in July. The final Act is expected to be published still before the year end. In that way, the majority of the measures can come into force on 1 January 2018. The corporate tax reform which is now voted is part
Belgium’s corporate tax reform: final steps ahead!
Last Friday, 8 December, the Council of Ministers reached an agreement on the final details of the major tax reform announced earlier in July 2017. This agreement comes after the advice from the Council of State and will in the coming weeks be debated in Parliament. The final acts are expected to be published by
ECOFIN Council’s publication of the EU list of third country non-cooperative jurisdictions in tax matters
On 5 December 2017, the ECOFIN Council published its conclusions on the EU common list of (third country) non-cooperative jurisdictions in tax matters, also referred to as the ‘blacklist’ consisting of 17 jurisdictions. This initiative forms part of the EU’s broader agenda on furthering tax transparency, fair taxation and the implementation of anti-BEPS measures with the
Final call for tax prepayments for assessment year 2018!
Companies with a year-end closing on 31 December 2017 can still make an advance tax payment for the fourth quarter of the year before 20 December 2017 to avoid a tax surcharge. For assessment year 2018, a global surcharge of 2,25% will be applied to the total amount of tax due (minus certain tax credits –