BEPS webcast series: A focus on treaty benefits
The OECD recently released its discussion draft on the use of treaty benefits in inappropriate circumstances. In response to this draft, part of the Base Erosion and Profit Shifting (BEPS) Action Plan, we will hold another webcast in our series, exploring the OECD’s Coordinated Action Plan on BEPS. Date: 7 April 2014 Time: 12:00 pm
OECD discussion drafts may impact private equity arrangements
The OECD released draft reports between 14 March 2014, and 19 March 2014, as part of the Base Erosion and Profit Shifting program that call for substantial changes to domestic tax rules, double taxation agreements, and amendments to the OECD Model Tax Convention and Commentary. If the recommendations are widely adopted, they will have a
Investment deduction percentages for assessment year 2015 published
On 26 March 2014, the new percentages for investment deduction, applicable to assessment year 2015 (income year 2014), were published in the Belgian Official Gazette. Generally speaking, to the extent specific legal conditions are met, Belgian companies or Belgian branches of foreign companies can deduct above the normal amortisation rules an extra percentage of the
OECD releases two discussion drafts on hybrid mismatch arrangements
The two draft reports released on 19 March 2014 by the OECD call for the introduction of both domestic rules and amendments to the OECD Model Tax Convention to neutralize the effect of hybrid mismatch arrangements. The recommendations of the OECD on hybrid mismatch arrangements result from Action 2 of the Action Plan on Base
Tax authorities target the partial exemption of remittance of Belgian withholding taxes
The amount of Belgian withholding taxes is based on the withholding income tax scales published in a Royal Decree. The Belgian income tax code foresees several exemptions (overtime, research and development, night and shift work, …) with respect to the remittance of Belgian withholding taxes. In this respect, it should be noted that the Belgian tax
Belgian tax authorities can copy and seize computerised information of taxpayers
The Belgian tax authorities have a broad view on their investigation powers as regards to computerised information. Recent case law seems to approve this broad view. After the tug-of-war between the Belgian taxpayers and the Belgian tax authorities regarding the competences of the latter to investigate, copy and seize computerised (digital) information, it seems that
Panel debate on the changing Belgian TP landscape
On 25 February 2014, a flagship event was held reflecting on the changing transfer pricing (TP) environment in Belgium. Two senior representatives from the Belgian administration and one delegate from the Organisation for Economic Cooperation and Development (OECD) shared interesting insights during a panel debate on how they feel that the Base Erosion and Profit Shifting (BEPS) project
Public comments on the OECD TP documentation and CbC Reporting
On 30 January 2014, the OECD invited comments from interested parties on the Discussion Draft on transfer pricing documentation and country-by-country reporting related to Action point 13 of the BEPS Action Plan. On Monday 03 March 2014, the OECD published the comments received, which will be discussed by Working Party No. 6 of the Committee on
