Modification to ELTIF Regulation: Trilogues are ready to start
On 25 May 2022, the Council reviewed and validated the Commission’s proposal amending Regulation (EU) 2015/760 on European long-term investment funds (ELTIF), following which the Economic and Monetary Committee of the EU parliament adopted its own position on the proposal on 20 June 2022. See our previous Newsflash for more information and background. Priorities In
The Luxembourg Reserved Alternative Investment Fund (RAIF) – Updated
Luxembourg RAIFs are increasingly used in order to provide debt funding for acquisitions. Until recently it was uncertain how interest paid by a Belgian company to a RAIF is to be treated from a Belgian withholding tax perspective. Two recent decisions of the Belgian Supreme Court provide more clarity. The RAIF Regime In 2016, Luxembourg
Tax Bites podcast: EU commission proposal to tackle the debt-equity bias in taxation (DEBRA)
In this week’s podcast, our speakers discuss the content of the proposal and assess which businesses will be impacted. They’ll explain the allowance on equity and interest limitation, linking this to other pending EU proposals. About the speakers: David Ledure, PwC Belgium Partner and leader of the global PwC Financial Transactions network Jean-Philippe Van West,
VAT fixed establishment – Positive decision of the ECJ in the “Berlin Chemie” case
The issue with parent-subsidiary VAT fixed establishment The concept of VAT fixed establishment has recently been the source of litigation in several Member States. In those cases, tax authorities argue that a subsidiary is the VAT fixed establishment of its parent company. In Belgium, we have seen this growing trend whereby the Belgian VAT authorities
Update: Extension till 16 May 2022 granted for the filing of the Summary statement 325.48 by qualifying Digital platform operators
In previous alerts we informed you that in anticipation of DAC7 specific reporting obligations apply in Belgium for digital platform operators since 2021. Under these rules, qualifying digital platform operators have to inform service providers active on the platform on their fiscal and social obligations. In addition, they have to send annually to these service
Tax Bites Podcast: Pillar Two model rules
Commentary to the OECD Pillar 2 Model Rules and recent Ecofin meeting On 14 March the OECD released the long-awaited Commentary to the OECD Pillar 2 Model Rules. One day later a revised version of the EU draft directive seeking to implement Pillar 2 into the EU was discussed at the ECOFIN meeting. In this
A great jumpstart to 2022: Belgium adopts a new tax framework for ELTIFs
Before Christmas, there was good news on the tax and economic front: a draft law on various tax provisions proposing to extend the tax regime of Belgian regulated investment funds to “European long-term investment funds” (ELTIFs) was presented to parliament. The draft law was adopted yesterday, meaning that Belgium’s now well-equipped with the appropriate investment
Tax Bites Podcast: Proposed implementation of the minimum tax in the EU and the unshell proposal
On 22 December, the European Commission issued 2 proposals. One proposal deals with the introduction of the global minimum tax in the EU by 2023. The EU proposal deviates from the OECD proposal on a number of topics. Find out how the proposal will look like in this Tax Bites episode with Jean-Philippe van West and
