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
Royal Decree on Public Country by Country Reporting published
On 6 June 2024, the Royal Decree on public country by country reporting (PCbCR) was published in the Belgian official gazette (See also our earlier messages on the introduction of public country by country reporting in Belgium of 4 June 2021 and 17 November 2023). This Royal Decree modifies the Royal Decree of 29 April
Short-term deposits volumes are peaking in the Euro Area. How can an internal cash pool play a role?
Recent data published by the European Central Bank (“ECB”) indicates that the volume of short-term deposits made by non-financial companies (“NFCs”) in the euro area is reaching its peak. Similar trends are observed from the intra-group perspective, when international groups opt for an internal cash pool as one of the cash management solutions. In order
Belgian law amending the investment deduction and innovation income deduction regime published in the Official Gazette
On 29 May 2024, the law of 12 May 2024 containing various tax provisions was published in the Belgian Official Gazette. This law implements several changes to the regime of the investment deduction and the innovation income deduction (IID). Key features of the new legislation are summarized below. For more information, we refer to our
The first Belgian Pillar 2 compliance milestone is out: notification at the Crossroads Bank of Enterprises (KBO/BCE)
Last year, Belgium officially enforced the Pillar 2 rules introducing a minimum tax for multinational companies and large domestic groups further to the publication of the law in the Belgian Official Gazette (Belgisch Staatsblad / Moniteur Belge) in December 2023. To comply with the requirements, groups in scope of the rules have to register at
