Belgium issues further guidance on Form 275 CBC NOT for entity liquidations
On 22 May 2026, the Belgian tax administration released additional guidance on the interpretation of the Country-by-Country Notification requirements (Form 275 CBC NOT), adding a third specific situation to the previously issued administrative clarification of 27 January 2026. As a reminder, the Belgian tax administration had already clarified how the option ‘termination of your notification obligation’ should be applied in two specific scenarios:
CJEU rules in Stellantis: transfer pricing adjustments are not automatically consideration for VAT-taxable services
On 13 May 2026, the Court of Justice of the European Union (“CJEU”) issued its judgment in Stellantis Portugal (C-603/24), another important case on the VAT treatment of transfer pricing adjustments. Stellantis Portugal purchased vehicles from European group manufacturers and resold them to independent Portuguese dealers. Where vehicles were affected by manufacturing defects, warranty issues
Tax bites podcast – Transfer Pricing audits
New Tax Bites episode out now! Pieter sits down with transfer pricing experts Ann and Brecht, and legal expert Véronique, to explore the changing Belgian TP audit landscape. Discover what happened to the traditional February audit “wave”, how audits are evolving and which companies and topics are being targeted. Get practical tips on prevention, managing
Belgium extends the filing deadline of the QDMTT and IIR Top-up Tax returns to 30 September 2026
What happened? The Belgian tax authorities have announced an extension of the filing deadline for the Qualified Domestic Minimum Top-up Tax (“QDMTT”) return and the Income Inclusion Rule (“IIR”) Top-up Tax Return. For returns for which the statutory filing deadline falls before 30 September 2026, the deadline has been extended to 30 September 2026. The due date
Introducing Our New Monthly Trade and Customs Insights Series
Your window into trade and customs trends Navigating the fast-moving world of global trade, customs, and regulatory change can be complex. Our mission is to make it simpler for your business. That’s why we’re launching a new monthly Trade & Customs Insights report, now available on our PwC Website. Each edition provides a clear, curated overview of the latest developments in
Belgium Publishes Draft IIR Top-Up Tax Return for Public Consultation
On Thursday 19 March 2026, the Belgian tax authorities published the draft Income Inclusion Rule (“IIR”) top-up tax return and accompanying explanatory notice for assessment year 2024 (covering fiscal years starting at the earliest on 31 December 2023 and closed at the latest on 30 December 2024) and 2025 (covering fiscal years starting at the earliest on 31 December 2024 and closed at
U.S. Supreme Court Strikes Down IEEPA-Based Tariffs: Constitutional Limits, Political Reaction, and What Comes Next for EU–US Trade
The U.S. Supreme Court has ruled that the administration exceeded its authority under the International Emergency Economic Powers Act (IEEPA) when imposing broad-based tariffs, including so-called “reciprocal” duties affecting the European Union and numerous other trading partners. The judgment is more than a technical trade decision. It is a constitutional clarification of the limits of
Tax bites podcast – International Tax Strategy for 2026: Aligning global tax policy changes with business operations
This podcast covers key points from our 6 February 2026 international tax webinar, including the Side‑by‑Side Package, updates on trade and tariffs, work mobility, and changes to the OECD Commentary. We also discuss expectations for 2026. If you’re interested in learning more or accessing the full webinar recording, please contact one of the presenters. Listen here: https://www.pwc.be/en/services/tax-and-legal/tax-bites-podcast-series/episode-62-international-tax-strategy-for-2026-aligning-global-tax-policy-changes-with-business-operations.html About the speakers
