Debt waivers without a tax cash out (?)
Last week, Belgian Minister of Finance Van Peteghem announced to extend the scope of the existing Belgian tax exemption for debt waivers to non-judicial debt reorganizations. This is very relevant for debt restructurings involving Belgian debtors, especially as the 2018 Belgian tax reform introduced a cap on the amount of certain tax attributes (such as
Brexit does not only impact fishing territories but also M&A transactions
During the holidays and after lengthy negotiations, the EU and the UK agreed on a Brexit – deal. As foreseen, on 1 January 2021, the transition period during which the UK was still considered a Member State of the EU and European Economic Area (EEA) has ended. Among a variety of topics, this is
New solidarity tax on security accounts?
Although the text is still in an early draft phase and still needs to be approved by the council of ministers, it was made public in the press that the idea of the new security tax seems to be a tax on the ownership of security accounts. The text of the pre-proposal is not yet
High net worth individuals on the radar of Vivaldi!
One of the measures announced by the newly formed government (“the Vivaldi coalition”) is the taxation of the major financial transactions (“MFTT”). Although only the main principles of this tax are known at this stage, the purpose would be to tax high net worth individuals. The impact of the tax is estimated between 150 to
Carry-back of losses: law published – listen to our podcast
On 1 July 2020, the law on the temporary tax exemption of profits in anticipation of tax losses realized in the COVID-19 period (the so-called tax loss “carry-back” system) was published in the Belgian Official Gazette. The new law aims to strengthen the liquidity and solvency of companies that were in a sound condition but
COVID-19 #13 Liquidation of negative net equity companies
In many groups, the current year financial performance will not meet the budget set at the start of the financial year. The current crisis is immeasurably affecting the economic landscape. When companies are no longer capable of funding their own operations, shareholders may be called to provide financial support. In circumstances like these, it is
COVID-19 #1 Debt waiver: beware for a tax cash out
Next to having a huge impact on our personal and family lives, the outbreak and spreading of the coronavirus (COVID-19) is likely to result in a slowdown of economies across the globe. In the coming weeks, we will keep you informed on various tax (re)structuring related topics that may help you in combating the virus
Limitation of tax losses in case of partial demerger
A partial demerger is a transaction whereby part of the assets and liabilities of the partially demerged company are transferred to another (acquiring) company, which (in principle) issues shares to the parent company of the partially demerged company. In case of a tax-neutral partial demerger, the carried forward tax losses of the partially demerged company
