On 16 May 2019 the Luxembourg Prime Minister Xavier Bettel and the Belgian Prime Minister Charles Michel have agreed to reopen negotiations regarding the double tax treaty concluded between Belgium and Luxembourg, with respect to the taxation of individuals working in a cross-border context. Belgian-Luxembourg double tax treaty In principle, employees who are tax resident
Fundamental changes to international tax structure ahead following OECD project on digitalisation of the economy
On 31 May 2019, the 129 members of the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting (BEPS) released a Programme of Work to develop a consensus solution to the tax challenges arising from the digitalisation of the economy. The Programme of Work was endorsed at the G20 meeting of finance ministers in Japan
On 2 May 2019, Belgium completed the implementation process of the Directive on tax dispute resolution mechanisms in the EU (Council Directive 2017/1852 of 10 October 2017). This enhanced procedure for resolving cross-border direct tax disputes puts taxpayer rights at the forefront, has a broader scope of application as well as an obligation for the
On 6 May 2019, the legislative documents implementing the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (also known as the MLI) was finally approved by all 6 legislative authorities in Belgium. The Belgian law ratified the full application of the MLI and its Explanatory Note, the reservations and notifications made by
European Commission announces final State aid decision on financing income exemption within the UK’s CFC rules
On 2 April 2019, the European Commission (EC) announced that the Group Financing Exemption (GFE) within the UK Controlled Foreign Company (CFC) rules is “partly justified”. The decision has not yet been published but a brief explanation of the decision can be found via this link.
On 7 March 2019, the European Commission (EC) announced the opening of an in-depth State aid investigation in a number of tax rulings granted by Luxembourg to Huhtamäki. This decision is another important decision in a range of decisions dealing with the taxation of intra-group financing activities. A brief explanation of the decision can be found