Arm’s length character of interest rates on intercompany loans
In recent years, the Belgian Tax Authorities (BTA) have intensified their focus on the (intercompany) financing arrangements of MNE groups. Some recent Belgian case laws offer valuable insights into the approach that the BTA and the Courts adopt when assessing the arm’s length character of intercompany financing conditions. Stay informed and adapt strategically! Judgment of
Deadline for first DAC7 reporting now imminent
DAC 7 recap In previous alerts we informed you that the DAC7 reporting obligation impacts various digital platforms operators. The scope of this obligation relates in a broad sense to platforms (any software, including a website, application, and so forth) that facilitate, directly or indirectly, the connection between sellers and buyers for the carrying out
Circular letter relating to the settlement of cross-border tax disputes in the European Union
On 1 December 2023, the Belgian tax authorities issued a circular letter (2023/C/95) relating to the settlement of cross-border tax disputes in the European Union. This circular letter provides clarification to help overcome the difficulties that may arise in the interpretation or application of the law of 9 May 2019 implementing Council Directive (EU) 2017/1852
Tax Bites Podcast – New Administrative Guidance on Pillar 2 and new timeline Pillar 1 – Amount A
A first critical look at the items addressed by the Administrative Guidance! In this episode, we share our first impressions of the Administrative Guidance on Pillar 2 published by the OECD on Monday 18 December 2023. A wide range of issues related to transitional safe harbours, the GloBE Rules and the Commentary are addressed in
OECD issues a new package of Administrative Guidance on Global Anti-Base Erosion Model Rules (Pillar 2)
On 18 December 2023, the OECD released the third package of Administrative Guidance. This third package follows the Administrative Guidance released in February and July. This guidance provides welcome clarification to the Pillar 2 rules, which will in many territories, including Belgium, come into force as from financial year 2024, The document addresses issues and
Tax Bites Podcast – Future-proofing your statutory reporting function (Part 5)
Future-proofing your statutory reporting function: managing transformations in the STAT & tax function In this fifth and final episode of our mini-series, we want to bring it all together. How do companies deliver in practice on the transformation of their STAT & tax function. How do they start such transformation projects? How do they manage
Belgian Federal Government approves law introducing a minimum tax for multinational companies (Pillar 2)
Yesterday, on 14 December 2023, Belgium approved the final law introducing a minimum tax for multinational companies and large domestic groups. This is the Belgian transposition of Council Directive (EU) 2022/2523 of 15 December 2022 ensuring a global minimum level of taxation for groups of multinational enterprises and large domestic groups in the European Union.
Tax Bites Podcast – Decoding CBAM: Navigating Carbon Pricing in the EU
Decoding CBAM: Navigating Carbon Pricing in the EU In this Tax Bites episode, we unravel the intricacies of the Carbon Border Adjustment Mechanism (CBAM) introduced by the European Commission. From targeted industries to a two-phase implementation, we break down why CBAM matters and its impact on businesses. Explore critical deadlines, challenges, and practical steps for
