EU Commission finds that Luxembourg gave State aid to GDF Suez (now Engie)
On 20 June 2018 the European Commission (“EC”) issued a press release concerning its final decision in the State aid investigation into tax rulings granted by the Luxembourg tax authorities to GDF Suez group (now Engie) (“the Group”) in relation to the treatment of certain financing transactions. The EC considered that the Group received an
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
Mandatory disclosure rules for intermediaries (DAC6) – Formal adoption
Today the Council has formally adopted Directive amending Directive 2011/16/EU as regards mandatory automatic exchange of information in the field of taxation in relation to reportable cross-border arrangements – also known as DAC6. In brief, these rules require us to report to the (Belgian) tax authorities certain transactions, assistance or advice. The Directive includes a
Belgian Transfer Pricing documentation requirements – FAQ published
The Belgian Tax Authorities have published a long awaited list of Frequently Asked Questions (FAQ) on their webpage dedicated to the Belgian Transfer Pricing documentation requirements. The FAQs are available in Dutch and French. This publication is quite important as it provides further guidance on how to deal with the Belgian transfer pricing documentation requirements
Local File for assessment year 2018 – Don’t wait until the due date is near!
In line with the three-tier documentation approach as provided under the OECD’s BEPS Action Point 13, Belgium has enacted specific transfer pricing (TP) documentation requirements into its tax law. This alert focuses on the Local File, which specifically requires reporting on intercompany transactions. Given the complexity of the matter, we recommend not waiting until the
OECD releases additional guidance on the attribution of profits to a permanent establishment under BEPS Action 7
On 22 March 2018, the OECD released the report Additional Guidance on the Attribution of Profits to Permanent Establishments (BEPS Action 7). This report contains additional guidance on the attribution of profits to permanent establishments resulting from the changes to the definition of permanent establishment in the Report on BEPS Action 7 to Article 5 of the
EU Commission finds that Luxembourg granted unlawful State aid to Amazon
On 26 February 2018, the European Commission (EC) published the non-confidential version of its final decision issued on 4 October 2017 in the Amazon State aid investigation opened in October 2014. According to the decision, in the EC’s opinion, Luxembourg’s tax treatment of Amazon gave rise to State aid in the amount of up to
Upcoming due date for the electronic filing of the Master file and the Country-by-country notification: 31 March 2018
For the first year of filing of the new transfer pricing documentation, the Belgian tax authorities have granted an administrative extension for the Master file and the Country-by-country notification till the end of March. What? A Belgian entity of a multinational group exceeding at least one of the following criteria needs to submit a Master
