The OECD released ‘Blueprints’ on the tax digitalisation/globalisation project on Monday 12 October. These two Blueprints cover Pillar 1 and Pillar 2 in the project framework previously announced. Pillar 1 looks at the attribution of revenues to market jurisdictions. Pillar 2 deals with the imposition of a minimum tax. The Blueprints indicate the degree of
COVID-19 and cross-border employment: is Belgium heading for a “force majeure” approach with its neighbouring countries?
In our newsflash of 15 April 2020, we were pleased to inform you that the Netherlands and Germany came to a mutual agreement regarding a “force majeure” tolerance for cross-border employment situations that are impacted by the coronavirus (COVID-19) pandemic. The Dutch-German agreement certainly embodies the recent OECD recommendations of 3 April 2020 (see our
In our newsflash of 13 March 2020, we highlighted that since the COVID-19 outbreak, due to travel restrictions and quarantine measures, many companies find themselves confronted with unforeseen and forced changes in the working pattern of their employees who are unable to perform their duties in their “normal” country of employment, especially in surrounding countries
On the 31st of January 2020, after a two-day meeting held on 29 – 30 January, the OECD/G20 Inclusive Framework on BEPS issued a statement that updates the state-of-play regarding the work on tax challenges arising from the digitalization of the economy, and sets forth a revised work program on the Two-Pillar Approach. In this
The OECD has released its long-awaited final report on the transfer pricing aspects of financial transactions. The report will constitute the 10th chapter of the OECD Transfer Pricing Guidelines (as well as an additional section in Chapter I). It covers a wide range of financial transactions and provides guidance on critical aspects to be considered
On 8 November, the Organisation for Economic Co-operation and Development (OECD) Secretariat published a Public consultation document: the Global Anti-Base Erosion Proposal (‘GloBE’) (Pillar II) which seeks stakeholders’ views on the introduction of common global minimum tax rules across the more than 130 countries participating in the OECD Inclusive Framework. Such rules would operate through top-up taxes
The proposal seeks to allocate a greater share of taxing rights to the countries where consumers/users are located – regardless of a business’ physical presence there.
Tax dispute resolution – Belgium obtains positive peer review on its Mutual Agreement Procedure practice
Background Improving dispute resolution mechanisms as regards the application and interpretation of tax treaties is high on the agenda of the OECD and a number of countries. Under BEPS Action 14, there is a broad commitment to implement a minimum standard to strengthen the effectiveness and efficiency of Mutual Agreement Procedures (“MAP”). One of the