How key interest rate cuts and stabilising inflation might impact your transfer pricing policy
The past few years the financial markets have been characterised by a significant increase in interest rates battling the surge in inflation throughout the world. Since the arm’s length principle requires intercompany transactions to appropriately reflect current market conditions, these exogenous elements have led companies to update their financing policies and more specifically their transfer
Tax Bites Podcast – The Belgian government negotiations: what’s on the table?
The Belgian government negotiations are ongoing as we speak: what is in the ‘Nota De Wever’? Get a comprehensive overview from our experts in the latest edition of the tax bites podcast. Our experts reflect on how this can impact groups with Belgian activities. About the speakers Bart Van den Bussche Tim Van Sant Pieter
Super Nota of Bart De Wever – What was on the table?
In Bart De Wever’s “Super Nota,” the proposed tax reform introduces substantial changes to the existing tax system. This article summarises the tax measures that were under consideration and might be used as a starting point when negotiations start again. As political discussions are not final, the information presented here may be subject to change
Pillar 2 notification: Administrative tolerance until 16 September
On 29 May 2024, the Royal Decree was published requiring Belgian entities of a Multinational Group to register with the Crossroads Bank of Enterprises (KBO or BCE) in order to comply with the Pillar 2 compliance formalities within 30 days after the first day of the first year in scope of Pillar 2 (or before
OECD issues a fourth package of Administrative Guidance on Global Anti-Base Erosion Model Rules (Pillar 2)
On 17 June 2024, the OECD released the fourth set of Administrative Guidance on GloBE rules, with the intention of clarifying the operation of these rules. This package follows the Administrative Guidance sets released in February, July and December last year. It is the first package of Administrative Guidance following the publication of the Consolidated
The UN Ad Hoc Committee released the Zero Draft ToR for the UN Tax Framework Convention for Public Consultation
On 7 June 2024 the Bureau of the Ad Hoc Committee (‘the Bureau’) released a Proposal for the Zero Draft Terms of Reference for the United Nations Framework Convention on International Tax Cooperation (‘the Draft Terms’). UN Member States and other stakeholders are invited to provide comments by 21 June 2024. These comments will ultimately
Tax Bites Podcast – What’s going on at the UN? The draft Terms of Reference for negotiating a Framework Convention on International Tax Cooperation
In this episode, we share our first impressions on the ‘Zero Draft’ Terms of Reference (ToR) for a UN Framework Convention on International Tax Cooperation released by the United Nations (UN) on 7 June 2024. Furthermore, we provide a brief overview of other important international and European tax developments. Tune in to get our first take on
Pillar 2 rules in an M&A context: time for action!
The OECD’s Pillar 2 rules have introduced a global minimum effective taxation of 15% for multinational enterprises or large domestic groups. Urgent action should be taken by all groups subject to the new mandatory pillar 2 notification, which is due by 13 July 2024. But also in transactions, the potential impact of pillar 2 should
