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
15 January 2019 – Brexit Update – Brexit deal voted down!
Today, the UK’s House of Commons voted on Mrs. May’s Brexit deal. As widely expected, the Brexit deal was voted down. Although it’s still unclear what’ll happen next, the voting down of the deal requires that Mrs. May come back to the House of Commons with an alternative motion by next Monday, opening a door
Upcoming due date for electronic filing of BEPS 13 related documents: extended to 28 February 2019
With our newsflash of 12 November 2018 we drew your attention to the upcoming deadline for electronic filing of BEPS 13 related documents. The form 275 MF (and potentially the Master file) in relation to the financial year ended 31 December 2017 and the notification of the Country-by-Country reporting obligations in relation to the financial
Upcoming due date for electronic filing of BEPS 13 related documents: 31 December 2018
All BEPS 13 related documents will, in principle, have to be filed electronically via the MyMinfinPro-website of the Belgian tax authorities (without exceptions). What? A Belgian entity of a multinational group exceeding at least one of the following Belgian GAAP based criteria (during the financial year preceding the financial year most recently closed) needs to
DAC6 – EC’s feedback on the questions raised by Member States
On 24 September 2018, EU Member States dedicated the entire meeting of the European Commission (EC)’s Working Party IV to seeking more clarity from the EC concerning the interpretation of Council Directive 2018/822/EU of 25 May 2018 amending Directive 2011/16/EU as regards mandatory automatic exchange of information in the field of taxation in relation to
VAT deduction on deal fees for an aborted transaction
Ryanair incurred considerable deal fees in relation to an envisaged takeover of a competitor. The takeover failed. Ryanair claimed input VAT deduction on the professional costs incurred based on its intention to perform taxable transactions with input VAT credit. In relation to deal fees, generally, input VAT deduction is allowed if management services against consideration
Belgium launches pilot program on cooperative tax compliance
The Large Enterprises Division of the Belgian tax administration (“LE Division”) announced the launch of a two-year pilot project on cooperative tax compliance (Cooperative Tax Compliance Program – “CTCP”). The program is aimed at transforming the traditional approach of ex-post tax investigations towards a system of proactive, real-time and constructive dialogue on the tax affairs of corporates.
EU Direct Tax Newsalert: EU Commission finds that Luxembourg did not grant State aid to McDonalds
On 19 September 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 a Luxembourg subsidiary of the McDonald’s group in relation to the treatment of a branch established in the United States of America (“US”). The
