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
The UK tax authorities on July 11 published draft legislation and draft guidance for a digital services tax (DST) to become effective April 1, 2020. These are available for public consultation until September 5, 2019. The DST is expected to apply by default at 2% of deemed UK revenues derived in excess of £25m, where
On 19 June 2019, the Court of Justice of the European Union (CJEU) issued its judgments in Memira Holding (C-607/17) and Holmen (C-608/17) on Swedish “final tax” losses. A brief explanation of the decision can be found via this link.
On 6 June 2019, the legislative documents implementing the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (also known as the MLI) were finally approved by all six legislative authorities in Belgium. The Belgian law ratified the full application of the MLI and its Explanatory Note, the reservations and notifications made by
UK states that OECD agrees on substantial activity level required to benefit from preferential IP regimes
The Governments of Germany and the United Kingdom (UK) have, on 11 November 2014, shown their commitment to ensuring that the G20/OECD Base Erosion and Profit Shifting (BEPS) project is successfully concluded by the end of 2015. As such, they have issued a joint statement on 11 November, so as to take forward the pending
In Italy the bill for the 2015 Stability Law will introduce a “Patent Box” regime for companies performing R&D activities, either directly or in cooperation with universities. Both Italian and foreign companies (through a PE) would be able to benefit from the reduced effective income tax rate on profits generated by R&D projects. The exemption (50%)
The OECD recently released its discussion draft focused on the digital economy as part of the Base Erosion and Profit Shifting (BEPS) Action Plan. In response to this draft, we will hold another webcast in our series of BEPS related webcasts. Please join us on 17 April where we will review the latest discussion draft