OECD publishes proposal to rewrite international profit allocation rules
The proposal seeks to allocate a greater share of taxing rights to the countries where consumers/users are located – regardless of a business’ physical presence there.
The due date for filing both the Belgian (non-resident) corporate income tax return and the local form ‘275 LF’ for assessment year 2019 is approaching: are you in control?
Both the Belgian (non-resident) corporate income tax return and the transfer pricing local form ‘275 LF’ are due soon. Below is an overview of the filing requirements. Corporate income tax return Belgian companies (and non-resident entities) have the yearly obligation to file a Belgian (non-resident) corporate income tax return by the statutory deadline. Filing a complete,
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
Corrections to previously filed CbC Reports
On July 30th 2019, the Belgian Tax Authorities (“BTA”) communicated that the portal MyMinfin has been opened for the submission of corrections to Country-by-Country Reports (“CbCR”) filed in previous years. In addition, the BTA have published practical guidelines and examples for reporting entities on how to report these corrections to previously filed CbCR. These guidelines
Belgian Ratification of the MLI: Ratification document deposited at OECD on 26 June 2019
On 6 June 2019, the legislative documents implementing the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (also known as the MLI) were finally approved by all six legislative authorities in Belgium. The Belgian law ratified the full application of the MLI and its Explanatory Note, the reservations and notifications made by
Fundamental changes to international tax structure ahead following OECD project on digitalisation of the economy
On 31 May 2019, the 129 members of the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting (BEPS) released a Programme of Work to develop a consensus solution to the tax challenges arising from the digitalisation of the economy. The Programme of Work was endorsed at the G20 meeting of finance ministers in Japan
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
Update on submission of CbCR Notification (i.e. form 275 CBC NOT)
On 2 May 2019, a law was approved including an update on the notification obligation of each Belgian group entity of a multinational group with regard to filing a country-by-country report. The law was published in the Belgian official gazette on 15 May 2019. The above notification obligation, which is included in article 321/3 of