Reclaiming immovable withholding tax may reduce the cost of vacant real estate
When increased interest rates and relatively high indexation make the economic outlook uncertain, companies might look to cut unnecessary costs. Although the strong changes in indexation during 2023 seem to be mostly behind us – indexation currently averaging between 2 and 3% in Belgium – indexation still has a big impact on the tax situation
Pillar 2 rules in an M&A context: time for action!
The OECD’s Pillar 2 rules have introduced a global minimum effective taxation of 15% for multinational enterprises or large domestic groups. Urgent action should be taken by all groups subject to the new mandatory pillar 2 notification, which is due by 13 July 2024. But also in transactions, the potential impact of pillar 2 should
Recent changes to the Belgian CFC legislation can give rise to an increased tax burden of your investment
In case your Belgian company has a foreign participation which it controls and of which the effective tax rate is lower than 12.5%, based on the taxable profit of that foreign entity recalculated according to Belgian tax rules, an additional tax could arise on the undistributed passive income of the foreign participation. In other words,
External financing is increasingly more difficult to obtain. How does it impact transfer pricing policies?
According to the latest update of the quarterly bank lending survey of the European Central Bank (“ECB”), the loan application rejection rate within the Eurosystem continued to increase during the first quarter of 2024, albeit at a slower rate than the previous quarter. In addition, Euro area banks reported a small further net tightening of
Adapted tax provisions regarding ‘judicial reorganisations’ offer new opportunities… and challenges
Recent adjustments of tax provisions regarding ‘judicial reorganizations’ offer new opportunities and challenges for distressed companies and their creditors. Most of these adjustments, aligning tax law with the updated insolvency law, entered into force with retroactive effect to 1 September 2023. The law of 28 December 2023 containing various tax measures has adapted the tax
“Long-lease and lease-back” transactions: a powerful tool to boost your cash position, if tax leakage can be minimised
Introduction (at a glance) Within the domain of corporate finance, the concepts of “sale and lease-back” and “long-lease and lease-back” refer to a transaction whereby the owner sells, alternatively confers a long lease right on a fixed asset and leases it back from the buyer to regain the utilisation of the asset at hand. Such
Holding companies – VAT deduction methodology – Reporting obligations
Introduction By the end of June 2023, companies applying the real use VAT deduction method (cost allocation) for mixed taxable persons had to notify it to the Belgian VAT authorities. Now these companies also have to communicate a whole set of information to back-up this VAT deduction methodology. For VAT taxable persons that already applied
New ways to carving-out and integrating your business in Belgium not always tax neutral
In 2023, new ways of performing carve-out and integrating your business became possible from a legal perspective. Meanwhile the tax law has also been adapted to enable you to perform these new ways of reorganising your group structure tax-free. Nevertheless, still some problems remain and sufficient attention should be paid to the tax consequences of
