Latest news & developments
Pillar 2 rules in an M&A context: time for action!
The OECD’s Pillar 2 rules have introduced a global minimum effective taxation of 15% for multinational enterprises or large domestic groups. Urgent action should be taken by all groups subject to the new mandatory pillar 2 notification, which is due by 13 July 2024. But also in transactions, the potential impact of pillar 2 should
Royal Decree on Public Country by Country Reporting published
On 6 June 2024, the Royal Decree on public country by country reporting (PCbCR) was published in the Belgian official gazette (See also our earlier messages on the introduction of public country by country reporting in Belgium of 4 June 2021 and 17 November 2023). This Royal Decree modifies the Royal Decree of 29 April
Short-term deposits volumes are peaking in the Euro Area. How can an internal cash pool play a role?
Recent data published by the European Central Bank (“ECB”) indicates that the volume of short-term deposits made by non-financial companies (“NFCs”) in the euro area is reaching its peak. Similar trends are observed from the intra-group perspective, when international groups opt for an internal cash pool as one of the cash management solutions. In order
Belgian Tax Authorities publish additional (and much welcomed) guidelines in view of the Co-Operative Tax Compliance Programme and details on what they consider to be a “mature” Tax Control Framework (TCF)?
Flashback to 2018 – What is the CTCP? With its launch in 2018 and with the ultimate goal of (i) achieving faster legal certainty for companies and (ii) improving compliance with tax obligations, the Belgian Co-operative Tax Compliance Programme (CTCP) introduced a mindshift, from a reactive tax audit modus to a collaborative, proactive approach based
Belgian law amending the investment deduction and innovation income deduction regime published in the Official Gazette
On 29 May 2024, the law of 12 May 2024 containing various tax provisions was published in the Belgian Official Gazette. This law implements several changes to the regime of the investment deduction and the innovation income deduction (IID). Key features of the new legislation are summarized below. For more information, we refer to our
The first Belgian Pillar 2 compliance milestone is out: notification at the Crossroads Bank of Enterprises (KBO/BCE)
Last year, Belgium officially enforced the Pillar 2 rules introducing a minimum tax for multinational companies and large domestic groups further to the publication of the law in the Belgian Official Gazette (Belgisch Staatsblad / Moniteur Belge) in December 2023. To comply with the requirements, groups in scope of the rules have to register at
It’s official : the new copyright regime does not apply to the IT sector
The Constitutional court rejects the actions introduced by several software designers and IT companies for the cancellation of the legislative provision which excludes income relating to computer programs from the specific copyright tax regime. Officially back to its roots The new copyrights regime has been modified by the program-law of 26 December 2022 (see our
Recent changes to the Belgian CFC legislation can give rise to an increased tax burden of your investment
In case your Belgian company has a foreign participation which it controls and of which the effective tax rate is lower than 12.5%, based on the taxable profit of that foreign entity recalculated according to Belgian tax rules, an additional tax could arise on the undistributed passive income of the foreign participation. In other words,
