European Commission opens State aid investigation into Luxembourg’s tax treatment of Huhtamäki
On 7 March 2019, the European Commission (EC) announced the opening of an in-depth State aid investigation in a number of tax rulings granted by Luxembourg to Huhtamäki. This decision is another important decision in a range of decisions dealing with the taxation of intra-group financing activities. A brief explanation of the decision can be found
Circular 2019/C/14 – Addendum to the circular 2017/C/56 containing additional guidance on the transfer pricing documentation penalty regime
On 8 February 2019, an addendum to the circular was issued containing additional guidance on the transfer pricing documentation penalty regime. General All companies and permanent establishments must prepare transfer pricing documentation unless they meet certain thresholds for exemption from filing documentation. Failing to file (in due time) the transfer pricing documentation (i.e. country-by-country report
Upcoming due date for electronic filing of BEPS 13 related documents: 28 February 2019
Transfer pricing documentation has become an integral part of the compliance obligations of Belgian entities. The deadlines, criteria and formalities should therefore be followed up closely. Please find below a short summary of the obligations to be complied with by 28 February 2019. What? Belgian entities – if they meet certain criteria – have to
Upcoming due date for electronic filing of BEPS 13 related documents: extended to 28 February 2019
With our newsflash of 12 November 2018 we drew your attention to the upcoming deadline for electronic filing of BEPS 13 related documents. The form 275 MF (and potentially the Master file) in relation to the financial year ended 31 December 2017 and the notification of the Country-by-Country reporting obligations in relation to the financial
The Belgian Ruling Office has granted a decision on the new CFC regime
Last week, the Belgian Ruling Office granted an advanced tax decision (not published yet) recognising the non-application of the upcoming Belgian CFC (‘Controlled Foreign Company’) law for two foreign companies owned by a Belgian parent company. Salient points of this decision This advance tax decision covering the inapplicability of the CFC regime is of particular
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
