Belgian Council of Ministers approves Multilateral Agreement on Exchange of CbCR
Today, 24 February 2017, the Belgian Council of Ministers has agreed on a preliminary draft of the law approving the Multilateral Competent Authority Agreement on the exchange of Country-by-Country (CbCR) reports. On 27 January 2016, Belgium had signed this Agreement in Paris in the framework of the OECD BEPS (“Base Erosion and Profit Shifting”) Action
New double tax treaty signed between Belgium and Japan
On 12 October 2016, the new Belgium-Japan Income Tax Treaty was signed in Tokyo during the Belgian economic mission. Once in force and effective, the new treaty will replace the old Belgium-Japan Income Tax Treaty (1968) as amended by the protocols signed in 1998 and 2010. The treaty will enter into force 30 days after
OECD releases discussion draft on branch mismatch structures
On 22 August 2016, the OECD published, for discussion, recommendations for domestic laws that would neutralise the effect of payments involving certain branch mismatch arrangements. This expansion of the final Base Erosion and Profit Shifting (BEPS) Action 2 paper, Neutralising the Effects of Hybrid Mismatch Arrangements, issued on 5 October 2015, adds even more complexity
New patent income deduction (PID) regime: Innovation Income Deduction
As from 1 July 2016, the existing Belgian patent income deduction (‘PID’) regime has been abolished (Official Gazette of 11 August 2016, 2nd ed.). Indeed, in line with the so-called ‘modified’ nexus approach, the current patent box regime had to be replaced with a BEPS (in particular Action Point 5 of the OECD BEPS Action
OECD releases discussion draft on interest deductions in banking, insurance sectors
On 28 July the OECD released a discussion draft relating to deductions for interest in the banking and insurance sectors. This is part of the ongoing work for BEPS Action 4, Limiting Base Erosion Involving Interest Deductions and Other Financial Payments, which was released as a final report in October 2015. The discussion draft does
Lost in Transactions – Your one-stop guide for everything you need to know about BEPS and M&A
We are pleased to announce that M&A Tax & Legal Services just finalised a publication which will guide you in everything you need to know about BEPS and M&A. ‘Lost in transactions’ is a practical guide to managing M&A deals in today’s global, digital world. Please find more information and the PDF version of the
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
EU Member States reach agreement on mandatory automatic exchange of financial information on country-by-country reporting (CbCR)
On 8 March 2016, the Member States of the European Union reached a political agreement on the automatic exchange of country-by-country reporting (CbCR) at a meeting of the Ministers of Economic and Financial Affairs in Brussels. The CbC reports contain tax-related financial information of multinational companies. The agreement is, however, still subject to the scrutiny
