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
Upcoming due date for electronic filing of BEPS 13 related documents: 31 December 2018
All BEPS 13 related documents will, in principle, have to be filed electronically via the MyMinfinPro-website of the Belgian tax authorities (without exceptions). What? A Belgian entity of a multinational group exceeding at least one of the following Belgian GAAP based criteria (during the financial year preceding the financial year most recently closed) needs to
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
The due date for both the Belgian corporate income tax return and the local form for assessment year 2018 is approaching: are you in control?
Corporate income tax return Belgian companies (and non-resident companies) have the yearly obligation to file a Belgian corporate income tax return within the statutory deadline. Filing a complete, timely and well-documented tax return is not only important to avoid penalties for not applying the correct tax treatment on a wide variety of expenses (and to
Last steps in the Belgian corporate tax reform taken before the summer recess
Just before the holiday period, the Belgian Chamber adopted the final text of the corporate tax reform that was initiated last year. As expected, a new Act amends and supplements the Corporate Income Tax Reform Act and the Program Act, both published end of December 2017. Some of the very last changes introduce new anti-abuse
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
