New ‘60-day rule’ for pension funds: the practice note was published
Quick recap Since 1 January 2017, a specific anti-abuse prevents to benefit from a WHT exemption when the Belgian tax administration proves that the dividends concerned are linked to a (set of) legal act(s) that are not genuine and aimed, even incidentally, at benefiting from the WHT exemption concerned. Since 22nd January 2019, the fact
Royal Decree of 8 May 2018: Private Pricafs get a boost
Private Pricafs (Pricafs Privées / Private Privaks) are investment vehicles aimed at encouraging investments in risk capital and private equity. Due to certain regulatory features, the creation of Private Pricafs did not really take off since their appearance. To correct this situation, a Royal Decree including several adjustments on the regulatory side but also a
Refund requests of Belgian WHT filed by non-residents: administrative guidance published
The Belgian tax administration has just published on its website a guidance (FR/NL) related to refund requests of Belgian WHT on dividends, interest and royalties filed by non-resident taxpayers. In particular, the Belgian tax administration has made a distinction between refund requests of Belgian WHT based on Double Tax Treaties and those based on Belgian
Taxation of French-sourced dividends: foreign tax credit available according to the Belgian Supreme Court
On 16 June 2017, the Belgian Supreme Court has reversed the current case law related to the granting of a foreign tax credit in Belgium with respect to foreign-sourced dividends received by Belgian private investors. The case concerned French-sourced dividends which, today, are normally taxed at a rate of 15% in France before being taxed
Draft Program Act of 3 June 2013
Following the agreement on the federal budget plan for 2013, which we discussed in our HRS Headline of 4 April 2013, the Federal Government has now submitted draft legislation ( bill ) to Parliament, proposing new tax measures. The bill includes both the introduction of a uniform (withholding) tax rate of 25% (instead of the
Belgian Budget Control 2013 – new measures
After a new and challenging budget negotiation process, the Federal Government has recently reached an agreement on the federal budget plan for 2013. In this respect, amongst others the following two fiscal measures were announced. Firstly, the Federal Government has decided to apply a uniform (withholding) tax rate to liquidation bonuses as from 1 October
