ECOFIN fails to reach agreement on anti-hybrid measure to be implemented into the Parent-Subsidiary Directive – FTT first on shares and some derivatives
1. Background On 25 November 2013, the European Commission has proposed to amend the EU Parent-Subsidiary Directive (‘PSD’) in order to tackle tax fraud/evasion and aggressive tax planning/base erosion and profit shifting (‘BEPS’) within the European Union. The proposal sought to insert (i) a specific anti-abuse rule for hybrid loan arrangements resulting in a double
Practice note issued in relation to Belgian fairness tax
As from AY14 (which are financial years ending 31 December 2013 or later), a so called ‘fairness tax’ of 5.15% is levied on certain dividend distributions made by large Belgian companies or by foreign companies with a Belgian permanent establishment, when the underlying profits have not been effectively taxed due to tax losses or Notional
BEPS Webcast – A focus on the digital economy, 17 April 2014
The OECD recently released its discussion draft focused on the digital economy as part of the Base Erosion and Profit Shifting (BEPS) Action Plan. In response to this draft, we will hold another webcast in our series of BEPS related webcasts. Please join us on 17 April where we will review the latest discussion draft
BEPS webcast series: A focus on treaty benefits
The OECD recently released its discussion draft on the use of treaty benefits in inappropriate circumstances. In response to this draft, part of the Base Erosion and Profit Shifting (BEPS) Action Plan, we will hold another webcast in our series, exploring the OECD’s Coordinated Action Plan on BEPS. Date: 7 April 2014 Time: 12:00 pm
OECD discussion drafts may impact private equity arrangements
The OECD released draft reports between 14 March 2014, and 19 March 2014, as part of the Base Erosion and Profit Shifting program that call for substantial changes to domestic tax rules, double taxation agreements, and amendments to the OECD Model Tax Convention and Commentary. If the recommendations are widely adopted, they will have a
Investment deduction percentages for assessment year 2015 published
On 26 March 2014, the new percentages for investment deduction, applicable to assessment year 2015 (income year 2014), were published in the Belgian Official Gazette. Generally speaking, to the extent specific legal conditions are met, Belgian companies or Belgian branches of foreign companies can deduct above the normal amortisation rules an extra percentage of the
EU Council of Ministers adopts new rules on the taxation of savings income
The EU Council of Ministers has adopted a Directive strengthening EU rules on the exchange of information on savings incomes, aimed at enabling the Member States to better clamp down on tax fraud and tax evasion. This follows a European Council agreement reached on 20 March. For further information see the Council press release, the
OECD releases two discussion drafts on hybrid mismatch arrangements
The two draft reports released on 19 March 2014 by the OECD call for the introduction of both domestic rules and amendments to the OECD Model Tax Convention to neutralize the effect of hybrid mismatch arrangements. The recommendations of the OECD on hybrid mismatch arrangements result from Action 2 of the Action Plan on Base
