Tax bites podcast: International tax update
This podcast highlights the main topics discussed and insights gained during PwC’s International Tax Webinar of 1 July 2026, which focused on a number of important recent developments in the area of European and international tax law and transfer pricing. This episode of the podcast first provides an update on the state of play regarding Pillar Two compliance, where efforts continue despite the filing deadline of 30 June. Subsequently, a
Council position on proposed CBAM expansion: what businesses need to know
On 12 June 2026, the Council agreed its position on proposed changes to the EU Carbon Border Adjustment Mechanism (“CBAM”). If adopted, the changes would make CBAM relevant to a much wider group of businesses as from 2028. In particular, CBAM would no longer be focused mainly on basic materials such as steel and aluminium, but would also apply to selected finished
Tax Bites Podcast – European Tax Omnibus proposal
The European Commission’s proposal for a Tax Omnibus Directive has been leaked ahead of its official publication later this month. The Tax Omnibus Directive aims to simplify the EU direct tax framework, reduce compliance costs for businesses and, ultimately, improve the EU’s competitiveness. To that end, it proposes to amend six existing direct tax directives in
Tax bites podcast – CBAM Unpacked: What it is and why it matters now
Welcome to the first episode of our new Tax Bites mini-series dedicated to the Carbon Border Adjustment Mechanism (CBAM) and the broader EU carbon taxation landscape. In this opening episode, Pieter sits down with our CBAM experts, Helena and Aurélien to set the stage: how does CBAM fit into the wider EU Green Deal and
Conflicting Belgian case law on transfer of excess interest deduction capacity – EU court to decide
The application of the 30% EBITDA interest limitation continues to give rise to significant uncertainty in Belgian acquisition structures. This uncertainty has now been elevated to EU level, as the court of first instance of Walloon Brabant has decided to refer a prejudicial question to the Court of Justice of the European Union. Under the
Belgian Court confirms: you can transfer more ‘interest deduction capacity’ than you have
In Belgian acquisition structures, the application of the 30% EBITDA interest limitation creates significant uncertainty. Although the law permits the transfer of excess interest deduction capacity within Belgian groups even in excess of the transferring entity’s own capacity, the tax authorities have adopted a restrictive interpretation which is particularly negative for Finco’s. Recent case law
VAT exemption for financial intermediation: broader than you think
Versãofast (GC, 26 Nov 2025, T-657/24): a functional test. The recent Versãofast judgment (26 November 2025, General Court) clarifies the scope of the VAT exemption for credit intermediation. While the Court recalls that VAT exemptions must be interpreted strictly, it adopts a functional approach to “intermediation”, focusing on what the service enables rather than on
Pledged shares and the participation exemption — Antwerp Court confirms the common‑sense approach applied by the ruling commission
Based on a strict reading of the law, pledged shares are not taken into account to determine if a shareholder has sufficient participation to benefit from dividends received deduction and dividend withholding tax exemption. The administrative tolerance in this respect has recently been confirmed by the Court of Appeal of Antwerp. When a company takes out a loan to finance an acquisition, banks often require that (at least part of) the acquired shares are pledged as a collateral. Under Belgian tax law, pledged shares are not counted for
