OECD publishes (long awaited) additional guidance on hard-to-value intangibles and profit split methods
In view of landing on the Transfer Pricing track in its work to curb Base Erosion and Profit Shifting (BEPS Actions 8-10) the OECD published two new reports on 21 June 2018: Guidance for tax administrations on the application of the approach to hard-to-value intangibles; and Revised guidance on the application of the profit split
EMEA ITS Webcast – How mandatory disclosure for intermediaries (DAC6) impacts multinationals
As per our previous update, the ECOFIN Council formally adopted – on 25 May 2018 – the directive on mandatory automatic exchange of information in the field of taxation in relation to reportable cross-border arrangements – also known as DAC6. As the directive will already enter into force in the next weeks and will have an
Mandatory disclosure rules for intermediaries (DAC6) – Formal adoption
Today the Council has formally adopted Directive amending Directive 2011/16/EU as regards mandatory automatic exchange of information in the field of taxation in relation to reportable cross-border arrangements – also known as DAC6. In brief, these rules require us to report to the (Belgian) tax authorities certain transactions, assistance or advice. The Directive includes a
Belgian tax reform reduces corporate rate to 25% and introduces fiscal consolidation
On 26 July 2017, the federal government reached an agreement on an important tax, economic and social reform package. A significant gradual reduction in the corporate income tax rate to 25% in 2020 and fiscal consolidation are key components of the package. The agreement preserves the notional interest deduction. The tax reform is built around
Belgium decides to reduce corporate tax rate from 34% to 25%
Remark: The following announced measures will have to be formalised in draft legislation which should only be available as from September/October. Only then will full details be known. On 26 July 2017, the Federal government reached an agreement on an important corporate tax reform, significantly reducing the corporate tax rate. More details will follow below.
Uncertainty over Income Tax Treatments: IFRS
The IASB recently issued a new Interpretation on Uncertain Tax Treatments (IFRIC 23). In short, it is the IFRS equivalent of the US GAAP Interpretation, ASC 740 (formerly FIN 48). IFRIC 23 was ratified in the IASB meeting on 16-17 May 2017, and issued on 7 June 2017. It will be effective for annual reporting
Belgian Fairness Tax: Status Quaestionis (update)
As a recall, by request sent to the Constitutional Court, a Belgian taxpayer company has filed in January 2014 an action for annulment of the so-called Belgian ‘Fairness Tax’. This action comprises four different causes of action each of them including different headings or arguments: European law: freedom of establishment and Parent-Subsidiary Directive; Constitutional law:
Ruling Office – rulings delayed due to annulation of French-speaking Board members
On 28 April 2017, the Belgian Council of State annulled the nomination of the French-speaking Board members of the Ruling Office, due to a complaint by a previous Board member. As a result of the judgement, the Ruling Office will not be able to take any formal decisions before the Board members have been replaced.
