Belgian Ratification of the MLI: a Game Changer in the International Tax Field
On 6 May 2019, the legislative documents implementing the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (also known as the MLI) was finally approved by all 6 legislative authorities in Belgium. The Belgian law ratified the full application of the MLI and its Explanatory Note, the reservations and notifications made by
Belgian tax administration publishes draft circular letter on transfer pricing
On 9 November 2018, the Belgian tax administration published a draft circular letter on the 2017 version of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (2017 OECD TPG). Interested parties are invited to send their comments on the draft to international.taxation@minfin.fed.be by 12 December 2018. Attention needs to be paid that
OECD publishes long-awaited public discussion draft on the transfer pricing aspects of financial transactions
On 3 May 2018, the OECD published a long-awaited public discussion draft on the transfer pricing aspects of financial transactions. With this publication, the OECD has reached another important milestone in the BEPS saga. As all groups have such transactions, the importance of the discussion draft cannot be underestimated. The discussion draft has been developed
OECD releases the draft contents of the 2017 update to the OECD Model Tax Convention
The OECD announced that earlier this week, on 11 July 2017, the OECD Committee on Fiscal Affairs released the draft contents of the 2017 update to the OECD Model Tax Convention (‘MTC’) prepared by the Committee’s Working Party 1. The draft contents of the 2017 update to the OECD MTC has not yet been approved by
2017 edition of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations
On 10 July 2017, the Organisation for Economic Cooperation and Development (OECD) announced that it released the 2017 edition of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (OECD TPG). The 2017 edition is a consolidated version of the various changes resulting from the OECD/G20 BEPS Project. In this respect, in particular the following
Draft MLI positions of different territories reflect a range of views on BEPS implementation
As a result of a new legal instrument, changes to the allocation of taxing rights and the introduction of new anti-avoidance rules mean that, once ratified, businesses and individuals may no longer qualify for double taxation relief on a range of cross-border transactions and activities. Taxable presences, compliance burdens, and tax liabilities could increase, and
OECD publishes additional guidance on Country-by-Country reporting (BEPS Action 13)
On 6 April 2017, the OECD has published further guidance for tax administrations and MNE Groups on Country-by-Country (CbC) reporting (Base Erosion and Profit Shifting (BEPS) Action 13). The guidance was released by the Inclusive Framework, which brings together over 100 countries and jurisdictions to collaborate on the implementation of the OECD/G20 BEPS Package. The
Belgian Council of Ministers approves Multilateral Agreement on Exchange of CbCR
Today, 24 February 2017, the Belgian Council of Ministers has agreed on a preliminary draft of the law approving the Multilateral Competent Authority Agreement on the exchange of Country-by-Country (CbCR) reports. On 27 January 2016, Belgium had signed this Agreement in Paris in the framework of the OECD BEPS (“Base Erosion and Profit Shifting”) Action