Latest news & developments
Insights into the OECD final report on branch mismatch structures
The OECD, on 27 July 2017, released its report, Neutralising the Effects of Branch Mismatch Arrangements Action 2 (see previous coverage). The report recommends domestic law changes to neutralise the effect of certain payments or deemed payments involving branches. These recommendations are not a minimum standard, but some countries may choose to adopt all or
Act published modifying the Belgian Net Asset Tax
Update – As announced in our Newsflash of 27 June 2017, the Belgian annual tax on undertakings for collective investment (the Belgian ‘Net Asset Tax’ or ‘NAT’) would be adapted with the following measures: Introduction of a reduced tax rate of 0.01% on institutional share classes of foreign undertakings for collective investment (provided the units
Refund requests of Belgian WHT filed by non-residents: administrative guidance published
The Belgian tax administration has just published on its website a guidance (FR/NL) related to refund requests of Belgian WHT on dividends, interest and royalties filed by non-resident taxpayers. In particular, the Belgian tax administration has made a distinction between refund requests of Belgian WHT based on Double Tax Treaties and those based on Belgian
Belgian Act on the exchange of tax rulings and country-by-country reports formally adopted
On 11 August 2017, a Bill was published in the Belgian Official Gazette implementing into Belgian tax law several EU Directives (see previous coverage) regarding the automatic and compulsory exchange of information in the field of taxation. The Bill formally transposes (i) Directive 2015/2376/EU, the so-called DAC 3, and (ii) part of the Directive 2016/881/EU, the so-called DAC
Protocol to Belgium-Switzerland Double Tax Treaty enters into force
According to the Swiss Federal Department of Finance the additional protocol to the Double Tax Treaty (‘DTT’) between Belgium and Switzerland, that has been signed on April 10, 2014 has entered into force as of July 19, 2017 and will generally apply as from January 2018. In general terms, the protocol brings the current DTT,
Belgian tax reform: Personal income tax – profit participation premium
Remark: the following announced measure will have to be formalised in draft legislation which should only be available as from September/October. Only then will full details be known. As already mentioned in the PwC Newsflash of 4 August, the federal government reached an agreement on 26 July 2017 on important tax, economic and social reform
Double Tax Treaty Belgium – the Netherlands: application of the 183-days rule
When a tax resident of Belgium is physically carrying out (a part of) his or her employment activities abroad, it should be determined if and to what extent the work state may levy income taxes. Based on article 15 of The Belgian-Dutch double tax treaty, employment income derived by a tax resident of Belgium will
Belgian tax reform: impact on M&A
The Belgian government has reached an agreement on an important tax, economic and social reform package. The contemplated changes aim to boost the Belgian economy through an investment friendly climate, but could also significantly impact deal structuring and due diligence processes. The highlights of the contemplated tax reform are the gradual reduction of the Belgian corporate
