COVID-19 #14 Impact of decreasing EBITDA on interest deductibility
You don’t need a crystal ball to predict that a lot of companies will be confronted with a lower EBITDA than projected. Especially for highly leveraged businesses, this may bring some additional challenges. Indeed, by transposing the interest limitation rules embedded in the EU Anti-Tax Avoidance Directive (‘ATAD I’) in national law, Belgian taxpayers may
COVID-19 #5 Cash repatriation
Although various listed groups have already announced to refrain from distributing dividends to their shareholders, centralising cash within the group is likely marked as a high priority item on every corporate agenda. Multinational groups may currently be revisiting their cash repatriation policy / advancing dividend distributions to get ahead trapped cash issues – e.g. arising
Belgian tax reform – Recap of corporate income tax measures applicable from 1 January 2019
A new year typically entails new tax measures. Below you will find a brief overview of some important Belgian corporate income tax measures that have entered into force, or are expected to enter into force, in 2019 (as part of the second phase of the Belgian tax reform). For a detailed overview of the measures,
The Belgian Ruling Office has granted a decision on the new CFC regime
Last week, the Belgian Ruling Office granted an advanced tax decision (not published yet) recognising the non-application of the upcoming Belgian CFC (‘Controlled Foreign Company’) law for two foreign companies owned by a Belgian parent company. Salient points of this decision This advance tax decision covering the inapplicability of the CFC regime is of particular
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
Council agrees its position on hybrid mismatches with third countries
On 21 February 2017, the Council of the EU, meeting through its Economic and Financial Affairs (ECOFIN) Council, agreed its position on rules aimed at closing down ‘hybrid mismatches’ with the tax systems of third countries (so called ATAD II). Following to the European Commission’s proposal on amendments to the Anti-Tax Avoidance Directive (ATAD) as
Anti-Tax Avoidance Directive: impacts on the real estate industry
EU countries reach political agreement on Anti-Tax Avoidance Directive: impacts on the real estate industry The EU-28 Finance Ministers reached political agreement on 21 June 2016 on the Council Directive laying down rules against tax avoidance practices that directly affect the functioning of the internal market (also known as ATAD). Ministers decided not to include
ATAD: what does it actually mean for financing?
On 21 June, the Economic and Financial Affairs Council (ECOFIN) reached a consensus on the “Anti-Tax Avoidance Directive” (ATAD). Some of the measures of this Directive directly affect groups’ existing financing set-ups. The main impact is the implementation of BEPS Action 4 via a Directive, which will impose a general interest deduction limitation. Member States