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
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