The recent developments in the international tax world are clearly finding their way into the Belgian tax investigation practice. PwC observes a significant increase in tax audits in which the Belgian tax authorities are focusing on passive income flows (dividend, interest and royalty) and alleged tax abuse through the involvement of intermediary entities. A number
Belgian requirements for payments to ‘tax havens’ As from 1 January 2010, companies subject to Belgian corporate income tax or Belgian non-resident corporate income tax are obliged to declare direct or indirect payments exceeding EUR 100,000 to recipients established in so-called ‘tax havens’. The reporting obligation applies to both cash payments and payments in kind.
Starting in 2012, political interest has increasingly focused on the opportunities provided by an automatic exchange of information between tax authorities. On 6 September 2013, the G20 Leaders committed to the automatic exchange of information as the new global standard and fully supported the OECD work for developing a single standard for automatic exchange of