U.S. Supreme Court Strikes Down IEEPA-Based Tariffs: Constitutional Limits, Political Reaction, and What Comes Next for EU–US Trade
The U.S. Supreme Court has ruled that the administration exceeded its authority under the International Emergency Economic Powers Act (IEEPA) when imposing broad-based tariffs, including so-called “reciprocal” duties affecting the European Union and numerous other trading partners. The judgment is more than a technical trade decision. It is a constitutional clarification of the limits of
Tax bites podcast – International Tax Strategy for 2026: Aligning global tax policy changes with business operations
This podcast covers key points from our 6 February 2026 international tax webinar, including the Side‑by‑Side Package, updates on trade and tariffs, work mobility, and changes to the OECD Commentary. We also discuss expectations for 2026. If you’re interested in learning more or accessing the full webinar recording, please contact one of the presenters. Listen here: https://www.pwc.be/en/services/tax-and-legal/tax-bites-podcast-series/episode-62-international-tax-strategy-for-2026-aligning-global-tax-policy-changes-with-business-operations.html About the speakers
Belgium issues administrative clarification regarding the new form 275 CBC NOT
On 27 January 2026, the Belgian tax administration released updated guidance on the interpretation of the amended Country-by-Country Notification (“CbC Notification”) requirements (Form 275 CBC NOT). This follows the introduction of the amended Form 275 CBC NOT earlier in 2024 (New Royal Decree of 16 June 2024). As a reminder, all Belgian constituent entities within multinational enterprise (MNE) groups must submit a CbC Notification if the MNE group is subject
Tax Bites Podcast – Inside the OECD Pillar 2 Side-by-Side package: Key features and insights
This podcast episode provides an overview of the Pillar 2 Side-by-Side agreement and its key features. We discuss the main points of the newly introduced safe harbors and highlight what listeners should watch for in the (near) future. Tune in for practical insights and essential takeaways on this important topic. Are you interested in learning more about the Side-by-Side package? Sign
Belgium partially repeals previously introduced updates to the form 275LF
On 7 December 2025, Belgium issued a new Royal Decree reversing several amendments introduced to the Belgian transfer pricing documentation forms by the Royal Decree of 16 June 2024, prior to these changes taking actual effect. Belgium’s transfer pricing documentation regime consists of the Local File Form (275 LF) and Master File (275 MF). Entities belonging to multinational groups with consolidated gross revenue of EUR
Will employees working from home trigger a PE? New commentaries from the OECD
In the wake of the COVID-19 pandemic, the rise in remote work has heightened the risk that companies may be deemed to have a permanent establishment (PE) in jurisdictions where employees regularly work from home, potentially triggering corporate tax filing and other registration/compliance obligations. To address these developments, the OECD has recently updated the commentary to
Belgium extends the filing deadline of the QDMTT return to 30 June 2026
What happened? Today, Belgium announced an extension of the deadline to file the Qualified Domestic Minimum Top-up Tax (“QDMTT”) return to 30 June 2026 for taxpayers with a financial year which: started at the earliest on 31 December 2023, and ended at the earliest on 1 January 2024 and at the latest on 30 June 2025. In its communication (available in Dutch and in French), the Belgian Ministry of Finance explains that this means
Ministry of Finance publishes Pillar 2 Circular Letter
On 22 October 2025, Belgium’s Federal Public Service Finance issued the Circular Letter 2025/C/68 providing extensive administrative guidance on the Belgian minimum tax regime for multinational enterprise (MNE) groups and large domestic groups (“the Pillar 2 Circular Letter”). The document has approximately 400 pages and is available in Dutch and French. It provides administrative guidance with
