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
Tax and Legal aspects of ESG in an M&A context – The deal Execution phase
In previous articles, we zoomed in on the importance of managing carefully the ESG (or at large “Sustainability”) hard and soft laws during the pre-deal phase of the M&A process. It was demonstrated that dealing/understanding the sustainability challenges during both the deal sourcing as well as the due diligence phase, actually contributes ultimately to
Possible important amendments to the stock option legislation and the introduction of a specific tax regime for free shares
A government proposal regarding new legislation with respect to stock options and stock plans was announced in the Belgian press last week (cf. please find the link to the entire article). It is however important to note that no texts are currently available and that it is currently not certain whether this proposal will eventually be
Possible important amendments to the stock option legislation and the introduction of a specific tax regime for free shares
A government proposal regarding new legislation with respect to stock options and stock plans was announced in the Belgian press last week. Below you can find a short overview of the proposed changes with some initial high-level reflections. It is however important to note that no texts are currently available and that it is currently
