Notional interest deduction rate for tax year 2019 is 0,746%
The Belgian notional interest deduction (NID) rate for tax year 2019 (accounting years ending between 31 December 2018 and 30 December 2019, both dates included) would be 0,746%. For SMEs (Small and Medium-sized Enterprises), the NID rate would be 1,246% for tax year 2019. According to article 205quater, §2 of the Belgian Income Tax Code
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
CJEU rules on subject-to-tax requirement of Parent-Subsidiary Directive
On 8 March 2017, the Court of Justice of the European Union (“CJEU”) rendered its Judgment in Wereldhave Belgium and Others concerning the interpretation of the subject-to-tax requirement of the Parent-Subsidiary Directive (“PSD”) (C-448/15). The CJEU’s interpretation of the PSD’s subject-to-tax requirement is more severe than a mere formal subjective tax liability. However, the precise
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
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
Innovation income deduction, an opportunity for the financial sector!
The new corporate income tax regime labelled as ‘innovation income deduction’ (IID) is about to be enacted. Given its new scope of application, it opens new opportunities for the FS sector in Belgium. Indeed, the IID regime is now applicable to a broader range of intellectual property (IP) assets and, as such, could be of interest
Likelihood of US Tax Reform reaches new high
The results of the US elections in November caught many by surprise with unexpected outcomes. Few predicted Republican candidate Donald J. Trump would be elected to serve as the next President. Republicans also retained majorities in both the US Senate and US House of Representatives. Expectations were for a split government for another 4 years