Upcoming due date for electronic filing of BEPS 13 related documents: extended to 28 February 2019
With our newsflash of 12 November 2018 we drew your attention to the upcoming deadline for electronic filing of BEPS 13 related documents. The form 275 MF (and potentially the Master file) in relation to the financial year ended 31 December 2017 and the notification of the Country-by-Country reporting obligations in relation to the financial
Upcoming due date for electronic filing of BEPS 13 related documents: 31 December 2018
All BEPS 13 related documents will, in principle, have to be filed electronically via the MyMinfinPro-website of the Belgian tax authorities (without exceptions). What? A Belgian entity of a multinational group exceeding at least one of the following Belgian GAAP based criteria (during the financial year preceding the financial year most recently closed) needs to
OECD publishes long-awaited public discussion draft on the transfer pricing aspects of financial transactions
On 3 May 2018, the OECD published a long-awaited public discussion draft on the transfer pricing aspects of financial transactions. With this publication, the OECD has reached another important milestone in the BEPS saga. As all groups have such transactions, the importance of the discussion draft cannot be underestimated. The discussion draft has been developed
Rulings Office releases 2016 Annual Report
The latest annual report of the Belgian Ruling Office was issued on June 21st. Looking at the statistics, it is clear that 2016 was a positive year with an increase in both the number of rulings granted and the number of pre-filing meetings held. The increase in the number of positive decisions combined with the
OECD releases the draft contents of the 2017 update to the OECD Model Tax Convention
The OECD announced that earlier this week, on 11 July 2017, the OECD Committee on Fiscal Affairs released the draft contents of the 2017 update to the OECD Model Tax Convention (‘MTC’) prepared by the Committee’s Working Party 1. The draft contents of the 2017 update to the OECD MTC has not yet been approved by
2017 edition of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations
On 10 July 2017, the Organisation for Economic Cooperation and Development (OECD) announced that it released the 2017 edition of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (OECD TPG). The 2017 edition is a consolidated version of the various changes resulting from the OECD/G20 BEPS Project. In this respect, in particular the following
EU Parliament adopts resolution on public CbCR
In the fight to crack down on corporate tax avoidance, the European Parliament has voted in plenary that multinational companies should disclose tax information in each country they operate. Consequently, multinationals with a worldwide turnover of minimum EUR 750 million should publicly disclose how much tax they pay and where, including taxes paid outside the EU. Large firms
Draft MLI positions of different territories reflect a range of views on BEPS implementation
As a result of a new legal instrument, changes to the allocation of taxing rights and the introduction of new anti-avoidance rules mean that, once ratified, businesses and individuals may no longer qualify for double taxation relief on a range of cross-border transactions and activities. Taxable presences, compliance burdens, and tax liabilities could increase, and
