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
Last steps in the Belgian corporate tax reform taken before the summer recess
Just before the holiday period, the Belgian Chamber adopted the final text of the corporate tax reform that was initiated last year. As expected, a new Act amends and supplements the Corporate Income Tax Reform Act and the Program Act, both published end of December 2017. Some of the very last changes introduce new anti-abuse
OECD publishes long-awaited public discussion draft on the transfer pricing aspects of financial transactions
On 3 May 2018, the OECD published a long-awaited public discussion draft on the transfer pricing aspects of financial transactions. With this publication, the OECD has reached another important milestone in the BEPS saga. As all groups have such transactions, the importance of the discussion draft cannot be underestimated. The discussion draft has been developed
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
