New wave of Belgian transfer pricing audits
The Belgian tax authorities have recently initiated a new wave of transfer pricing audits. Many taxpayers have already or will soon receive an in-depth questionnaire requesting bulk taxpayer information in relation to their transfer pricing arrangements. This first request for information on intercompany transactions and the activities carried out by the Belgian company or branch
Belgian draft law amending the law introducing a minimum tax for multinational companies
On 6 March 2024, the Belgian government submitted a draft law to parliament, which is intended to amend the law of 19 December 2023 on the introduction of a minimum tax for multinational companies and large domestic groups. If the draft law is approved, it would be applicable to financial years starting on or after
CSDDD Gets the Green Light from the EU Council with Reduced Scope
As sustainability takes center stage in global policy conversations, there has been an increasing change in how businesses approach their social, environmental, and governance responsibilities. With today’s vote in the Committee of Permanent Representatives of the Governments of Member States to the European Union (COREPER), the European Council has de facto given the green light
OECD Published Guidance on Amount B
On 19 February 2024, the OECD published a report which aims to simplify and streamline the application of the arm’s length principle to in-country baseline marketing and distribution activities (the Report) (also known as Amount B under Pillar One). The first draft guidance and call for input dates back from late 2020. Quite some time
Harmonising Carbon Pricing in the CBAM Era: EU-Switzerland ETS Linkage
Recent developments in the Agreement between the EU and Switzerland on linking their Emission Trading Systems reflect an ongoing commitment inside the European Union to aligning carbon pricing strategies across borders, that is now expected to accelerate following the adoption and implementation of the Carbon Border Adjustment Mechanism (CBAM). The EU Carbon Pricing Strategy The
Deadline for first DAC7 reporting now imminent
DAC 7 recap In previous alerts we informed you that the DAC7 reporting obligation impacts various digital platforms operators. The scope of this obligation relates in a broad sense to platforms (any software, including a website, application, and so forth) that facilitate, directly or indirectly, the connection between sellers and buyers for the carrying out
Circular letter relating to the settlement of cross-border tax disputes in the European Union
On 1 December 2023, the Belgian tax authorities issued a circular letter (2023/C/95) relating to the settlement of cross-border tax disputes in the European Union. This circular letter provides clarification to help overcome the difficulties that may arise in the interpretation or application of the law of 9 May 2019 implementing Council Directive (EU) 2017/1852
Tax Bites Podcast – New Administrative Guidance on Pillar 2 and new timeline Pillar 1 – Amount A
A first critical look at the items addressed by the Administrative Guidance! In this episode, we share our first impressions of the Administrative Guidance on Pillar 2 published by the OECD on Monday 18 December 2023. A wide range of issues related to transitional safe harbours, the GloBE Rules and the Commentary are addressed in
