CJEU holds German RETT exemption for group restructurings not to be State aid in upstream merger case
On 19 December 2018, the Court of Justice of the European Union (CJEU) issued its judgment in the case of A-Brauerei (C-374/17). A brief overview of the judgment can be found via this PwC EUDTG Newsalert – 20 December 2018 (CJEU holds German RETT exemption_ for group restructurings not to be State aid in upstream merger_ case)
Wage withholding taxes for French residents, effective from 1 January 2019
A big change is coming for France. As from 1 January 2019, for French resident taxpayers, wage withholding tax (“prélèvement à la source” or PAS) will be applied on certain types of income (including employee’s remuneration). This measure, which was initially foreseen as of 1 January 2018 but postponed with one year, will impact many
Belgian tax administration publishes draft circular letter on transfer pricing
On 9 November 2018, the Belgian tax administration published a draft circular letter on the 2017 version of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (2017 OECD TPG). Interested parties are invited to send their comments on the draft to international.taxation@minfin.fed.be by 12 December 2018. Attention needs to be paid that
DAC6 – EC’s feedback on the questions raised by Member States
On 24 September 2018, EU Member States dedicated the entire meeting of the European Commission (EC)’s Working Party IV to seeking more clarity from the EC concerning the interpretation of Council Directive 2018/822/EU of 25 May 2018 amending Directive 2011/16/EU as regards mandatory automatic exchange of information in the field of taxation in relation to
Transitional law for expats under the current Dutch 30% ruling
In our Newsflashes of 24 April 2018 and 30 May 2018, we already referred to the announcement of the Dutch government that it will reduce the maximum duration of the 30% ruling, notably from 8 to 5 years, as of 1 January 2019. This proposed legislation to reduce the Dutch expat ruling will also apply to
Withholding tax evasion and avoidance: new measures announced
Last Friday, the Belgian Council of Ministers approved a draft bill of law aimed at fighting several situations of Belgian WHT (Withholding Tax) evasion and avoidance. The purpose of the new rules is to tackle improper WHT exemptions or refunds and facilitate the recovery of WHT in such cases. In a nutshell In a communication
Company provided housing: anticipated change in tax law
When a company puts a house or an apartment at the disposal of one of its directors or employees, a taxable benefit in kind arises in the hands of the beneficiary. Typically, the calculation of this benefit in kind depends on whether the housing is provided by an individual (100/60 x indexed cadastral income) or
Summer deal advances the implementation of the Belgian EBITDA rule by one year
In the context of its comprehensive political agreement reached last week, the Belgian Government decided to advance the implementation of the new interest limitation rule from 2020 to 2019 (i.e. financial years starting on or after 1 January 2019). The new Belgian interest limitation rule is the transposition of the EBITDA-based interest limitation rules included by
