New ‘60-day rule’ for pension funds: the practice note was published
Quick recap Since 1 January 2017, a specific anti-abuse prevents to benefit from a WHT exemption when the Belgian tax administration proves that the dividends concerned are linked to a (set of) legal act(s) that are not genuine and aimed, even incidentally, at benefiting from the WHT exemption concerned. Since 22nd January 2019, the fact
Annulment of the Fairness Tax by the Constitutional Court – Practice Note issued
For recall, on 1 March 2018, the Constitutional Court annulled the Fairness Tax but decided to maintain its effects for the assessment years 2014 to 2018, except in case of redistributions of dividends (see our newsflash in this respect). On 3 September 2018, the Belgian tax administration released a Practice Note commenting the content and
Withholding tax liability on income attributed to taxpayers subject to the legal entity income tax: recent developments
Who is liable to levy the withholding tax (“WHT”) on income attributed to taxpayers subject to the legal entity income tax? This question has been addressed by the Supreme Court in several (and opposite) decisions. On its side, the Belgian tax administration has consistently adjusted its stance on this matter in various Practice Notes, the
