New legislation impacting 30% EBITDA rule
In order to address criticism of the European Commission on inter alia the Belgian implementation of the “EBITDA interest limitation rule”, the Belgian legislator has published new legislation to address those. This might impact the financing of real estate, entities that perform factoring activities or entities active in “long-term public infrastructure projects”. The scope of
The OECD publishes its guidance on the transfer pricing implications of the COVID-19 pandemic
During the outbreak and spreading of the COVID-19 pandemic, many businesses faced or are facing significant cash flow constraints, disruption to their supply chains, or even forced (temporary) closing for business. The long-awaited OECD guidance on the transfer pricing implications of the COVID-19 pandemic was finally published on 18 December 2020. A plea for practical
Upcoming due date for electronic filing of BEPS 13 related documents: 31 December 2020
Transfer pricing documentation requirements have become an integral part of the compliance obligations of Belgian entities and branches. The criteria, formalities and deadlines should therefore be followed up closely. Please find below a short summary of the obligations to be complied with by 31 December 2020. What? A Belgian entity or Belgian branch part of a
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
The OECD published its blueprints on pillar 1 and 2 – get the latest insights via our webcast.
The OECD released ‘Blueprints’ on the tax digitalisation/globalisation project on Monday 12 October. These two Blueprints cover Pillar 1 and Pillar 2 in the project framework previously announced. Pillar 1 looks at the attribution of revenues to market jurisdictions. Pillar 2 deals with the imposition of a minimum tax. The Blueprints indicate the degree of
Publication of updated FAQs on Belgian documentation requirements
On 30 June 2020, the Belgian Tax Authorities published its Circular Letter 2020/C/88 containing an update of the Frequently Asked Questions (FAQ) (previous version dd. 4 May 2018) with respect to the Belgian transfer pricing documentation requirements on Country-by-Country Reporting (CbCR) (articles 321/1 to 321/2 BITC), the notification on CbCR (article 321/3 BITC), the Master
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
