Belgian Ratification of the MLI: a Game Changer in the International Tax Field
On 6 May 2019, the legislative documents implementing the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (also known as the MLI) was finally approved by all 6 legislative authorities in Belgium. The Belgian law ratified the full application of the MLI and its Explanatory Note, the reservations and notifications made by
CJEU holds German RETT exemption for group restructurings not to be State aid in upstream merger case
On 19 December 2018, the Court of Justice of the European Union (CJEU) issued its judgment in the case of A-Brauerei (C-374/17). A brief overview of the judgment can be found via this PwC EUDTG Newsalert – 20 December 2018 (CJEU holds German RETT exemption_ for group restructurings not to be State aid in upstream merger_ case)
Belgian tax administration publishes draft circular letter on transfer pricing
On 9 November 2018, the Belgian tax administration published a draft circular letter on the 2017 version of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (2017 OECD TPG). Interested parties are invited to send their comments on the draft to international.taxation@minfin.fed.be by 12 December 2018. Attention needs to be paid that
Multilateral transfer pricing audits: EU JTPF publishes recommendations
The EU Joint Transfer Pricing Forum (“EU JTPF” or “the Forum”) recently published its report “A coordinated approach to transfer pricing controls within the EU”, which aims to address the lack of guidance on bilateral and multilateral transfer pricing audits. The objective of the report, inspired by a number of successful pilot cases, is to
Belgium launches pilot program on cooperative tax compliance
The Large Enterprises Division of the Belgian tax administration (“LE Division”) announced the launch of a two-year pilot project on cooperative tax compliance (Cooperative Tax Compliance Program – “CTCP”). The program is aimed at transforming the traditional approach of ex-post tax investigations towards a system of proactive, real-time and constructive dialogue on the tax affairs of corporates.
OECD publishes long-awaited public discussion draft on the transfer pricing aspects of financial transactions
On 3 May 2018, the OECD published a long-awaited public discussion draft on the transfer pricing aspects of financial transactions. With this publication, the OECD has reached another important milestone in the BEPS saga. As all groups have such transactions, the importance of the discussion draft cannot be underestimated. The discussion draft has been developed
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
