OECD publishes (long awaited) additional guidance on hard-to-value intangibles and profit split methods
In view of landing on the Transfer Pricing track in its work to curb Base Erosion and Profit Shifting (BEPS Actions 8-10) the OECD published two new reports on 21 June 2018: Guidance for tax administrations on the application of the approach to hard-to-value intangibles; and Revised guidance on the application of the profit split
EU Commission finds that Luxembourg gave State aid to GDF Suez (now Engie)
On 20 June 2018 the European Commission (“EC”) issued a press release concerning its final decision in the State aid investigation into tax rulings granted by the Luxembourg tax authorities to GDF Suez group (now Engie) (“the Group”) in relation to the treatment of certain financing transactions. The EC considered that the Group received an
Wage cost reduction for shift labour in the construction sector
The Act of 26 March 2018 has introduced a specific regime for wage withholding tax exemption for shift labour in the construction sector. The legislation as existing in article 275/5 BITC regarding shift labour has thus been amended with an additional definition for shift labour in the construction sector. The Belgian tax administration issued on
Dual Pension Savings in Belgium – Practice Note
A dual system for pension savings has been introduced in Belgium by the law of 26 March 2018 (Official Gazette of 30 March 2018). Recently, the Belgian tax authorities issued a practice note (2018/C/72) which provides clarification and specific examples in this respect. The existing system for pension savings (pensioensparen / épargne-pension) is well known in
EMEA ITS Webcast – How mandatory disclosure for intermediaries (DAC6) impacts multinationals
As per our previous update, the ECOFIN Council formally adopted – on 25 May 2018 – the directive on mandatory automatic exchange of information in the field of taxation in relation to reportable cross-border arrangements – also known as DAC6. As the directive will already enter into force in the next weeks and will have an
Dutch 30% tax ruling: from 8 to 5 years – update
In our Newsflash of 24 April 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. It is anticipated that this reduced application will be applicable as of January 2019 for both new and existing employment situations
Belgian Tax Authorities announce some of their focus areas for 2018 tax audits
The Belgian Tax Authorities have recently announced some of their focus areas for 2018 for tax audits. This early warning allows both individual taxpayers and enterprises to ensure compliance with their Belgian tax obligations. Individuals and enterprises that have not filed tax returns will in any event be selected. Enterprises can expect to face more
Local File for assessment year 2018 – Don’t wait until the due date is near!
In line with the three-tier documentation approach as provided under the OECD’s BEPS Action Point 13, Belgium has enacted specific transfer pricing (TP) documentation requirements into its tax law. This alert focuses on the Local File, which specifically requires reporting on intercompany transactions. Given the complexity of the matter, we recommend not waiting until the
