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26 January 2024

Arm’s length character of interest rates on intercompany loans

In recent years, the Belgian Tax Authorities (BTA) have intensified their focus on the (intercompany) financing arrangements of MNE groups.  Some recent Belgian case laws offer valuable insights into the approach that the BTA and the Courts adopt when assessing the arm’s length character of intercompany financing conditions. Stay informed and adapt strategically! Judgment of

19 January 2024

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

18 January 2024

Navigating the evolving “De Minimis Regulation”: recent changes and future expectations

In the dynamic landscape of state aid, the De Minimis regulation has been put in place to ensure a fair competition between enterprises across the European Union. However, significant updates to the regulation have recently been made. Looking at the future, such changes promise to reshape how companies navigate this important aspect of state aid.

17 January 2024

CBAM – Calculation methods for the embedded emissions

The specific embedded emissions of goods produced in an installation are determined according to one of the following methods (Article 4(1) CBAM Implementing Regulation): a determination of the emissions from the source streams based on activity data obtained from laboratory analyses or standard values using measurement systems and calculation factors; or  a determination of the

15 January 2024

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

12 January 2024

Countdown Alert! The 1st CBAM Report deadline is less than 20 days away

Take a moment to assess your organisation’s reporting readiness! – Ensure which (all) of your entities need to report before the deadline. – Verify that you have access to the EU CBAM Reporting (CBAM Transitional Registry) for all of your reporting entities and the person(s) responsible. – Manage a base-level data for reporting so you

8 January 2024

Tax and Legal aspects of ESG in an M&A context – The deal Execution phase

  In previous articles, we zoomed in on the importance of managing carefully the ESG (or at large “Sustainability”) hard and soft laws during the pre-deal phase of the M&A process. It was demonstrated that dealing/understanding the sustainability challenges during both the deal sourcing as well as the due diligence phase, actually contributes ultimately to