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
OECD releases additional guidance on the attribution of profits to a permanent establishment under BEPS Action 7
On 22 March 2018, the OECD released the report Additional Guidance on the Attribution of Profits to Permanent Establishments (BEPS Action 7). This report contains additional guidance on the attribution of profits to permanent establishments resulting from the changes to the definition of permanent establishment in the Report on BEPS Action 7 to Article 5 of the
European Commission proposes new rules on the taxation of the digital economy
On 21 March 2018, the European Commission published its EU digital tax package on the taxation of the digital economy. The package contains among other things two new draft EU Directives for a comprehensive long-term solution (laying down rules relating to the corporate taxation of a “significant digital presence”) and a short term/interim solution to
Taxation of Dutch AOW pensions – Circular 8 March 2018
Certain taxpayers, who have been living and/or working in The Netherlands, may decide to move their residency from The Netherlands to Belgium and retire in Belgium. Over the years, there has been quite some discussion and uncertainty in the Belgian fiscal landscape with respect to the taxation of Dutch AOW pensions, paid to tax residents
EU finance ministers agree on mandatory disclosure for intermediaries (DAC6)
On 13 March 2018, EU finance ministers reached agreement on transparency requirements for tax intermediaries. The proposal (so called DAC6) is the latest of a number of measures designed to prevent corporate tax avoidance. It will require intermediaries such as tax advisors, accountants and lawyers to report tax planning schemes that could be aggressive and
EU Commission finds that Luxembourg granted unlawful State aid to Amazon
On 26 February 2018, the European Commission (EC) published the non-confidential version of its final decision issued on 4 October 2017 in the Amazon State aid investigation opened in October 2014. According to the decision, in the EC’s opinion, Luxembourg’s tax treatment of Amazon gave rise to State aid in the amount of up to
Upcoming due date for the electronic filing of the Master file and the Country-by-country notification: 31 March 2018
For the first year of filing of the new transfer pricing documentation, the Belgian tax authorities have granted an administrative extension for the Master file and the Country-by-country notification till the end of March. What? A Belgian entity of a multinational group exceeding at least one of the following criteria needs to submit a Master
Belgian corporate tax reform enacted by Parliament
On 22 December 2017, the Belgian Parliament approved the major corporate tax reform announced in July. The final Act is expected to be published still before the year end. In that way, the majority of the measures can come into force on 1 January 2018. The corporate tax reform which is now voted is part
