PwC’s Tax Bites podcast: Tax in 2021 – what to expect?
2020 was in many ways a challenging year, with several developments materialising in the tax domain. What will 2021 bring us in the area of taxation? Listen to our first Tax Bites podcast of the year to find out. In this episode, Pieter Deré is joined by Ellen Cortvriend, Gilles Franssens and Jean-Philippe Van West to take a closer look at the
Taxpayer relationship and tax audits in Belgium: what can we expect following the Belgian Minister of Finance’s policy note?
The Belgian Minister of Finance, Vincent Van Peteghem, has made his first official statements on the ambitions of the new government De Croo I in relation to the SPF/FOD Finance. Minister Van Peteghem, also in charge of the Coordination of the Fight against Fraud, presented his policy note on 4 November 2020 to the Belgian
National courts to interpret milestone EU Danish cases on beneficial ownership and abuse
On 26 February 2019, the Court of Justice of the European Union (CJEU) issued its judgments in the so-called “Danish cases”. The underlying question of these cases was whether dividend and interest payments could be exempt from withholding tax under the EU Parent Subsidiary and Interest & Royalty Directives, when the payments were made from
Belgian tax audits: increased focus on passive income streams and international cooperation
The recent developments in the international tax world are clearly finding their way into the Belgian tax investigation practice. PwC observes a significant increase in tax audits in which the Belgian tax authorities are focusing on passive income flows (dividend, interest and royalty) and alleged tax abuse through the involvement of intermediary entities. A number
Belgian transfer pricing audits: new wave initiated – Update
Our newsflash of 25 March 2020 informed you about the upcoming new wave of transfer pricing audits and the requests for information that were sent out. In the meantime, and in particular in light of the Covid-19 pandemie, we were informed that the BTA has suspended the sending out of the requests for information. For
Belgian transfer pricing audits: new wave initiated
Last week, the Belgian tax authorities have initiated a new wave of transfer pricing audits. Multiple taxpayers have already received or will receive in the next few days an in-depth questionnaire that focuses on their transfer pricing arrangements. The request for information on intercompany transactions and activities of the Belgian company or branch is the
Tax dispute resolution – Belgium obtains positive peer review on its Mutual Agreement Procedure practice
Background Improving dispute resolution mechanisms as regards the application and interpretation of tax treaties is high on the agenda of the OECD and a number of countries. Under BEPS Action 14, there is a broad commitment to implement a minimum standard to strengthen the effectiveness and efficiency of Mutual Agreement Procedures (“MAP”). One of the
Belgium implements new EU Tax Dispute Resolution Directive
On 2 May 2019, Belgium completed the implementation process of the Directive on tax dispute resolution mechanisms in the EU (Council Directive 2017/1852 of 10 October 2017). This enhanced procedure for resolving cross-border direct tax disputes puts taxpayer rights at the forefront, has a broader scope of application as well as an obligation for the
