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
OECD releases discussion draft on the use of treaty benefits in inappropriate circumstances
This OECD report calls for a very significant rewrite of both the OECD Model Tax Convention and the Commentary, including a US-style Limitation of Benefits (LoB) article as well as a main purpose anti-abuse rule. A variety of other anti-abuse measures are also proposed. If the recommendations are widely adopted, they will undoubtedly reduce treaty
Panel debate on the changing Belgian TP landscape
On 25 February 2014, a flagship event was held reflecting on the changing transfer pricing (TP) environment in Belgium. Two senior representatives from the Belgian administration and one delegate from the Organisation for Economic Cooperation and Development (OECD) shared interesting insights during a panel debate on how they feel that the Base Erosion and Profit Shifting (BEPS) project
Public comments on the OECD TP documentation and CbC Reporting
On 30 January 2014, the OECD invited comments from interested parties on the Discussion Draft on transfer pricing documentation and country-by-country reporting related to Action point 13 of the BEPS Action Plan. On Monday 03 March 2014, the OECD published the comments received, which will be discussed by Working Party No. 6 of the Committee on
Mandatory e-filing of income tax returns
Since assessment year 2005, Belgian corporate entities have the possibility to file their corporate income tax return electronically.
An interview with Pascal Saint-Amans on BEPS
Interview with Pascal Saint-Amans on the progress of the OECD on BEPS.
PwC Webcast on US international tax reform proposals
Join specialists from PwC to gain a better understanding of US international tax reform proposals…
Reporting obligation for payments to tax havens extended to Luxembourg, Cyprus, BVI and Seychelles
Background Since January 1, 2010, companies subject to Belgian corporate income tax or Belgian non-resident corporate income tax are obliged to declare (in form 275F) direct or indirect payments exceeding EUR 100,000 to recipients established in so-called ‘tax havens’ (article 307, §1, 4° of the Belgian Income Tax Code). The reporting obligation applies to both
