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
ECOFIN Council’s publication of the EU list of third country non-cooperative jurisdictions in tax matters
On 5 December 2017, the ECOFIN Council published its conclusions on the EU common list of (third country) non-cooperative jurisdictions in tax matters, also referred to as the ‘blacklist’ consisting of 17 jurisdictions. This initiative forms part of the EU’s broader agenda on furthering tax transparency, fair taxation and the implementation of anti-BEPS measures with the
Webcast on 27 November: “How US Tax Reform impacts European Multinationals”
As you may be aware, the Senate Finance Committee on 16 November 2017 approved a Senate version of US tax reform legislation. The Finance Committee action comes after the House of Representatives on the same day voted to pass the ‘Tax Cuts and Jobs Act’ (HR 1). These actions indicate Congress’s continued efforts to enact major
EU Directive on Tax Dispute Resolution Mechanisms formally adopted
On 10 October 2017, the ECOFIN Council formally adopted a Directive on tax dispute resolution mechanisms in the EU. The objective is to establish more effective and efficient procedures within the EU. The Directive builds on the existing Convention 90/436/EEC on the elimination of double taxation in connection with the adjustment of profits of associated
EU Commission takes next steps against Ireland and Luxembourg in Apple and Amazon State aid cases
On October 4, 2017, the European Commission (EC) continued its ongoing challenges to Member States’ transfer pricing tax regimes by advancing two high profile cases to the next stages. In the Apple case, the EC referred Ireland to the Court of Justice of the European Union (CJEU) for failing to enforce an August 2016 State aid recovery decision,
Circular letter on exit taxation
On 11 August 2017, an administrative circular letter was issued with respect to the Belgian exit taxation rules. Belgium amended, via the Act of 1 December 2016, the Belgian tax provisions on exit taxation largely in line with the Anti-Tax Avoidance Directive (ATAD) requirements on exit taxation. More precisely, the Act introduced amongst others the option
Insights into the EU proposal on mandatory disclosure of tax information by taxpayers and intermediaries
The European Commission, on 21 June 2017, published a draft Directive that would impose mandatory reporting by taxpayers and intermediaries to the tax administrations of EU Member States for various cross-border transactions and arrangements, and the automatic exchange of this information among Member States (see previous coverage). Taxpayers and intermediaries (such as consultants, banks, and
