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
OECD issues a new package of Administrative Guidance on Global Anti-Base Erosion Model Rules (Pillar 2)
On 18 December 2023, the OECD released the third package of Administrative Guidance. This third package follows the Administrative Guidance released in February and July. This guidance provides welcome clarification to the Pillar 2 rules, which will in many territories, including Belgium, come into force as from financial year 2024, The document addresses issues and
Belgium and The Netherlands agree on employees working from their home location
On November 23, 2023, the Competent Authorities (CA) of Belgium and The Netherlands signed an agreement* clarifying when a permanent establishment (PE) exists for the employer in the other country if employees are working from their home location in that other country. This agreement provides welcome additional guidance on the cases in which an employee
Tax Bites Podcast – How to get Pillar 2 ready: a step-by-step approach
How to get Pillar 2 ready: a step-by-step approach In this episode the speakers elaborate on PwC’s recently published Pillar Two Guide for EMEA Multinational Enterprises, which sets out the steps you need to take to be Pillar 2 compliant. About the speakers Gergely Juhasz Clayton Stanfield Hanne Schoepen Listen now Missed the previous
Expected change in Belgian CFC regime
A draft law was introduced into parliament to change the Belgian CFC regime, which was introduced as part of the EU Anti-Tax Avoidance Directive (hereafter “ATAD directive”) in 2017. The CFC regime Belgium introduced back in 2017 taxed non-distributed income arising from non-genuine arrangements which have been put in place for the essential purpose of
Packaging and Packaging Waste Regulation (PPWR): The EU Parliament adopts its position with view to the upcoming negotiations with the Council
In November 2022, the European Commission (EC) unveiled its proposal for a new Regulation on packaging and packaging waste (PPWR). This proposal, aimed at replacing the existing framework established in 1994, addresses the urgent need to harmonise divergent regulatory practices across member states, which have been creating significant barriers in the internal market for packaging,
Draft law on public country-by-country reporting in parliament
Introduction In our previous newsflash regarding the public country-by-country reporting (PCbCR) directive, we informed you that EU member states must introduce the directive in their domestic legislation by 22 June 2023 at the latest. Belgian PCbCR draft law On 10 November 2023, the Belgian draft law was finally published. As per the draft text, companies
